OMIG Published New Compliance Program Self-Assessment Form

The Office of the Medicaid Inspector General (OMIG) has recently published a new Compliance Program Self-Assessment form on its website. This form is designed to assist healthcare providers in evaluating the strengths and weaknesses of their compliance programs based on the regulations outlined in 18 NYCRR Part 521. Any provider generating in excess of $500,000 of Medicaid billing is required to have a Medicaid compliance program in place and should have their Medicaid compliance officer complete the Self-Assessment form to identify any areas where controls surrounding compliance should be strengthened.

Furthermore, providers are advised not to submit the completed Self-Assessment form to OMIG unless specifically requested to do so.

This Compliance Program Self-Assessment Form serves as a valuable tool for providers to assess the effectiveness of their compliance programs. It is important to emphasize that nothing in this form modifies or alters any statutory or regulatory requirements. In the event of any inconsistencies between the statutes, regulations, and this form, the obligations set forth in the statutes and regulations prevail.

All terms and acronyms used in the form, unless otherwise specified, should be understood in accordance with the definitions provided in Title 18 NYCRR Parts 504, 515, and 521.

Here are a couple of definitions to clarify certain terms within the form:
• “Appropriate Compliance Personnel” includes the compliance officer and compliance staff who directly report to the compliance officer.
• “MMCO” refers to any managed care provider or managed long term care plan.
• The questions in the form are organized according to the requirements outlined in 18 NYCRR SubPart 521-1.

We Recommend:

• That you have your Medicaid compliance officer complete the Self-Assessment form electronically using Microsoft Word. Ensure that you have relevant documentation to support your affirmative responses indicating that you meet the requirements.
• If you find that your organization does not meet a particular requirement, mark it as “No” and develop and implement appropriate plans to rectify the non-compliance.
• Providers are encouraged to include additional questions in the form that address specific compliance program issues they may encounter. However, it is not recommended to remove any questions from the provided form.
• Review the results of the Self-Assessment with your compliance committee and potentially your audit committee or Board (depending on which has oversight authority over Medicaid compliance).

Additional information and resources are available in the Compliance Library on OMIG’s website.