On August 21, 2023, the New York State Office of the Medicaid Inspector General (“OMIG”) updated its Medicaid Self-Disclosure Program Requirements. The updated Instructions and Guidelines announce a new “Abbreviated” Self-Disclosure process and forms as an alternative to the “Self-Disclosure Full Statement” process and forms.
The Self-Disclosure Abbreviated Statement’s use is limited to “errors that are more transactional or routine in nature and already repaid through voids or adjustments …”. OMIG identifies the following as examples when the Abbreviated Statement can be used:
- Routine credit balance/coordination of benefits overpayments;
- Typographical human errors;
- Routine Net Available Monthly Income (NAMI) adjustments;
- Instances of missing or faulty authorizations for services due to human error;
- Instances of missing or insufficient support documentation due to human error;
- Inappropriate rate, procedure or fee code used due to typographical or human error;
- Routine recipient enrollment issues.
The Guidelines do not specify minimum or maximum dollar values for use of the Abbreviated Self-Disclosure process.
The Self-Disclosure Full Statement format can be used for self-disclosures related to any overpayments and for disclosures related to damage, loss or destruction of records.
The Self-Disclosure Program Requirements Instructions & Guidelines August 2023 includes information on both Self-Disclosure methods, as well as information on how to identify overpayments, how to determine eligibility to self-disclose overpayment, links to forms for both methods, and other related matters.
Please contact Peter Hoffman at phoffman@harrisbeach.com or Matthew Babcock at mbabcock@harrisbeach.com if you would like to engage Harris Beach to assist you in making self-disclosures or if you would like any more information on OMIG’s Self-Disclosure processes.
This alert is not a substitute for advice of counsel on specific legal issues.
Harris Beach has offices throughout New York state, including Albany, Buffalo, Ithaca, New York City, Rochester, Saratoga Springs, Syracuse, Uniondale and White Plains, as well as Washington D.C., New Haven, Connecticut and Newark, New Jersey.