November 13, 2012

In two weeks, beginning on December 1st and prior to the New Year, practitioners who participate with Medicaid and claim or order, or have claimed or ordered more than $500,000 of straight Medicaid or Medicaid-HMO monies ("Required Providers") are required to once again certify that they have Medicaid compliant compliance programs implemented in their practice.  Medicaid's Mandatory Compliance requirement has been in effect since July 2009, and dictates procedures Required Providers must have on file, adopted and implemented in their practices, for the following: (1) billings; (2) payments; (3) medical necessity and quality of care; (4) governance; (5) mandatory reporting; (6) credentialing; and (7) other risk areas that are or should with due diligence be identified by the provider.  Click here for more information on Plan requirements.  Certification is done online on the Office of the Medicaid Inspector General website.  For those providers meeting the Required Provider definition who fail to adopt a plan and certify, OMIG is checking.  Failing to have a compliance plan may open your practice to liability including fines, sanctions and/or exclusion from Medicaid.  You may be thinking, how will Medicaid know if I do not have a plan or do not certify?  The answer is simple: Medicaid has computer generated lists of those providers required to comply, and Medicaid is checking that list and targeting providers. 

For assistance developing, implementing and certifying a compliance plan, visit our Compliance Page or contact our office.  Our firm has developed Medicaid compliant plans ready for customization for your practice.