MEDICAID PROVIDERS - OMIG to Conduct Effectiveness Reviews

February 17, 2012

February 17, 2012

This update includes a memo from Hiscock and Barclay and an edited version of al ACL UPDATE sent last October that points you in the direction of a self-auditing tool that you can use to prepare for a potential audit of the type described in the H&B announcement below.

FROM: Hiscock and Barclay

"Measuring the Effectiveness of a Compliance Program: OMIG Style"

As you may know, over the course of the last year, the New York State Office of the Medicaid Inspector General (OMIG) has issued guidance for providers regarding how OMIG would evaluate the effectiveness of a compliance program. OMIG now requires providers to certify the effectiveness of their compliance programs during December of each year. In recent months, OMIG has been conducting an increased number of “effectiveness reviews,” where it contacts a provider who is supposed to have an effective compliance program, and requires them, sometimes on an expedited basis, to complete the relevant OMIG effectiveness questionnaire and provide other documentation to the compliance effectiveness review team. A site visit may occur, which includes interviews of board members, management and staff and can last a week.

To read the entire text on this alert, click on this link: <http://www.hblaw.com/pdf/HCHS%202-15-12.pdf>

FROM ACL – modified from the original – NEW WORDING IS ITALICIZED AND IS FROM THE H & B MEMO

October 13, 2011 

OMIG: Provider Self-Assessment Tool

OMIG’s Bureau of Compliance is surveying provider compliance programs. This is separate from the Bureau of Audit that would audit your compliance with actual OMH and Medicaid regulations – this is only to assess the completeness of your compliance program that ensures that you are in compliance with Medicaid.

OMIG has put a self-assessment tool on their website for you to use to assess your compliance program. This is voluntary and meant to help you to be in compliance HOWEVER. OMIG may ask Medicaid providers for evidence of their self assessment as part of routine audits, routine investigations or routine Compliance Program effectiveness reviews. . . . Once the Provider Self Assessment Tool is completed, OMIG recommends that the compliance officer share the responses on the tool with the provider’s senior management and governing board.

Go to: http://www.omig.ny.gov/data/content/view/81/206/ and then click on the Compliance Program Assessment Tool – Focused Reviews

This is also the tool that they will use when, and if, they schedule a survey of your compliance program.

Category: ACL Updates