The New York State Office of the Medicaid Inspector General (“OMIG”) recently posted on its website a Compliance Program Self-Assessment Form that OMIG developed as a resource for providers to help them assess their compliance programs’ effectiveness under the new compliance regulations adopted on December 28, 2023. This form is different from the Compliance Program Review Module that OMIG published on March 8, 2023.

You will see similarities between the Compliance Program Review Module (which OMIG will use when doing its audits) and the Compliance Program Self-Assessment Form. OMIG does provide some basic direction to providers if their self-assessment determines that a requirement is not being met.

When accessing the Compliance Program Self-Assessment form in a Microsoft Word document, allow “editing” to enter information in the form.

OMIG clearly indicates that the Self-Assessment Form SHOULD NOT be submitted to OMIG.

Please contact Matthew Babcock at mbabcock@harrisbeach.com if you would like to engage Harris Beach to review your compliance plan or to assist in development of a compliance plan and supporting policies that meet the new requirements.

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, Long Island, New York City, Rochester, Saratoga Springs, Syracuse and White Plains, as well as Washington D.C., New Haven, Connecticut and Newark, New Jersey.