Start Now: Assess/Upgrade Compliance Before December
New York’s Office of the Medicaid Inspector General (OMIG) recently issued Compliance Alert 2012-01, which identifies the providers who must present the annual certification of an “effective compliance program” (as that term is defined by regulation) in December, and reminds them of this year-end responsibility.
Providers of goods and services, either directly to Medicaid or indirectly to Medicaid managed care organizations, who have submitted claims of at least $500,000 in any twelve-month period should review the regulations carefully to determine if they are required to make a certification.
If certification of an "effective compliance program" is required, it is now time to evaluate (and improve) the provider's compliance program. OMIG has provided a basic self-assessment tool to aid in that process. The assessment takes only a short time to complete and is worth doing sooner rather than later. By doing so, the compliance program can be upgraded if needed in order to meet “effective compliance program” standards by December.
Earlier blogs have discussed which providers must certify, and resources for compliance program gap analysis and review.