Analysis of New OMIG Self-Disclosure Guidance: Members-Only Resource

LeadingAge NY is making available to members a memorandum from our attorneys at Hinman Straub on recently issued updates to Office of the Medicaid Inspector General (OMIG) self-disclosure guidance. As previously reported here, OMIG updated previous guidance on its self-disclosure program in January 2024. The guidance has been issued in response to regulations adopted in December 2022 that strengthened requirements for Medicaid managed care plans and codified OMIG's self-disclosure program. The newest updates include (1) additional compliance information concerning managed care self-disclosure programs; (2) clarifications and new guidance regarding the "abbreviated” self-disclosure process; and (3) self-disclosure after the 60-day deadline. The memorandum highlights key elements of OMIG’s latest guidance and is not intended as a full summary of the referenced guidelines.

Contact: Karen Lipson, klipson@leadingageny.org