August 14, 2012

Today's newsletter is geared towards those of you accepting or referring for NYS Medicaid, however, the message applies to ALL providers for reasons to be explained.

It should come as no suprise that today's newsletter is about NYS Office of Medicaid Inspector General's compliance requirements and auditing activity, although for many the message does not seem to be registering.  To explain in simpler terms, many of you are required to have an OMIG compliant compliance program in place, for which you are required to take affirmative action confirming you have adopted, or OMIG may be knocking on your door.  In the newly released OMIG Work Plan, OMIG has named "Compliance Program Effectiveness Reviews" as a top priority to combat fraud for the 2012-2013 year.  Specifically, "OMIG will access in-house expertise in conducting compliance program effectiveness reviews of provider compliance programs. Effectiveness reviews will primarily focus on providers who fail to certify that they are meeting the obligation to implement an effective compliance program."   This message is not new.  In its July 2012 Compliance Alert, OMIG issued a stand-alone compliance bulletin to:

1. identify Medicaid providers who must have a compliance program and who must annually certify on OMIG’s Web site that their compliance program meets New York State’s mandatory compliance program requirement;
2. remind providers of their annual certification requirement during December each year;
3. advise newly enrolling Medicaid providers of the certification requirement;
4. recommend that providers conduct a self assessment of their compliance programs prior to completing the certification; and
5. provide a self-assessment tool that can be used by Medicaid providers as they conduct their selfassessment activities.

Medicaid requires providers receiving or ordering $500,000 or more of Medicaid monies (whether straight Medicaid or Medicaid HMO money) to have a compliance plan and certify same.  CLICK HERE FOR MORE INFORMATION.

The reason this email is important for all providers to read, regardless of whether you accept Medicaid, is that the level of current regulation is unprecedented, and proactive compliance is an easy and affordable way to protect your practice from unwanted scrutiny.  The compliance plan required for certain Medicaid providers is recommended for all providers.  It is a document designed to limit exposure for billing mistakes - double billing, upcoding, billing for medically unnecessary services, etc.  - all of the things payors and government agencies are auditing for now.  This document also appoints who is in charge of ensuring billing is performed correctly at the practice and details the proper lines of communications should a mistake be uncovered. 

Becase we are looking to encourage all listserv members to adopt compliance, we will extend a 15% discount on any compliance orders from our website - https://www.kirschenbaumesq.com/page/practice-compliance during the month of August.  We will also be hosting a webinar in September on proper compliance procedures, for which participation will be free for everyone who has ordered compliance from our firm in August.   Questions on compliance?  Please ask.