Final Reminder of Annual Certification Requirement for Compliance Programs and DRA Obligations

The New York State Office of the Medicaid Inspector General (OMIG) reminds Medicaid providers subject to New York’s mandatory compliance program obligation in Social Services Law Section 363-d and state regulations at 18 NYCRR Part 521 that the December Annual Certification period expires Dec. 31, 2016. Additionally, New York’s Medicaid providers subject to the Deficit Reduction Act (DRA) of 2005 must complete their DRA Annual Certification also by Dec. 31, 2016.

Information, instructions, and the certification forms required to meet the compliance program and DRA certification requirements are available on OMIG’s website at https://www.omig.ny.gov/compliance/certification.

OMIG also recently issued new Compliance Program Review Guidance for those Medicaid providers that are required to adopt and implement effective compliance programs as a condition of enrollment in the Medicaid program. The guidance provides details on how OMIG assesses provider compliance programs. It addresses the eight elements of a compliance program, as well as prime risk areas – billing, payment, medical necessity and quality of care, governance, mandatory reporting, credentialing – and other potential compliance risks. LeadingAge NY's legal counsel, Hinman Straub, has prepared a summary and analysis of the OMIG guidance for member reference.

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866