Corporate Compliance: Are you ready?

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The NYS OMIG has recently updated their integrity initiatives and work plan for providers and will continue to do so throughout the year in an effort to keep up with the changing Medicaid landscape.

One of their major focuses continues to be on collaboration with providers to enhance compliance. Providers are reminded that those subject to mandatory compliance programs are required to complete an annual certification (SSL Certification) each December on the OMIG website. Those who fail to do so may be at risk of administrative action and civil monetary penalties.

In addition, NYS OMIG reminds providers that they will continue to conduct compliance program reviews to ensure such programs are implemented and operating as required. Implementation of an effective Corporate Compliance Program involves a multifaceted approach.

Here are some key areas to include in your program:

• Written policies and procedures.

• Designation of a Compliance Officer.

• Training and education for all employees and persons associated with care delivery.

• Ensuring all employees have access to the Compliance Officer.

• Ensuring methods for anonymous reporting are in place.

• Establishment of a system for routine identification and auditing of risk areas.

• Establishment of a system for investigation and reporting to DOH/OMIG.

• Policies that encourage and protect employees for good faith participation.

In addition to current State requirements, CMS will be introducing new federal regulatory standards that include compliance with the new Compliance and Ethics regulations §483.85 in Phase 3 of the RoP in November 2019. Implementing a compliant and effective corporate compliance program can help you avoid deficiencies and financial penalties, help address high-target areas that may raise red flags for an auditor and improve overall quality of care. We encourage SNF providers to review their States OMIG website for more information or contact Coretactics for an analysis of your current program.

Sarah Ragone, MSPT, RAC-CT
VP of Reimbursement & Education

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