Corporate Compliance

NY requires compliance programs for Medicaid providers

Healthcare Auditing Weekly, February 3, 2009

New York Medicaid providers must implement a compliance program according to a new mandate from the New York Office of the Medicaid Inspector General (OMIG).
Medicaid providers who submit, or anticipate submitting, $500,000 in claims in a consecutive 12-month period must comply with the new requirement. According to the language published on the OMIG Web site, approved compliance programs should include all of the following: 
  • Written policies and procedures
  • A designated employee responsible for the day-to-day operation of the compliance program
  • Training and education for all affected employees and persons associated with the provider
  • Communication lines between the compliance position and all employees, including a method for anonymous and confidential good faith reporting of potential compliance issues
  • Policies to encourage good faith participation in the program
  • A system to identify compliance risk areas, including internal and external audits, and self-evaluations
  • A system for investigating potential compliance problems, as well as correcting the problems and implementing procedures to prevent future issues
  • A policy of non-intimidation and non-retaliation for good faith participation in the compliance program


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