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OMIG’s Compliance Program Guidance for Medicaid-Enrolled Providers

On December 28, 2022, the New York State Office of the Medicaid Inspector General (OMIG) issued new, detailed regulations that require Medicaid-enrolled providers and contractors of providers to maintain provider compliance programs and require Medicaid managed care organizations (MMCOs) to maintain fraud, waste, and abuse prevention programs and codify in regulation obligations to self-disclose Medicaid overpayments.

OMIG’s new Compliance Program Guidance outlines several best practices and provides examples of documentation that OMIG believes Medicaid required providers should maintain to demonstrate that have adopted, implemented, and maintain effective compliance programs that meet each of the 7 elements specified in the regulations.

You can find comprehensive guidance related to provider compliance programs, including the 7 elements, self-disclosure, and Medicaid managed care fraud, waste, and abuse prevention programs regulations on OMIG’s website.

We strongly recommend that providers perform a compliance program effectiveness review utilizing these new standards, as OMIG intends to commence compliance program audits of providers to assess their compliance with these new standards. OMIG indicated in a recent presentation that a score of less than 60% compliance may result in enforcement actions, and even a “passing” score likely will result in corrective actions.

If you are looking for a resource to assist with your compliance needs, Practicefirst recommends Healthcare Plan Design, LLC. Call or email Donna Wypych at 716-228-0818 or or go to

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