OMIG: Changes to OMIG’s Compliance Certification

Carl J. Pucci and Nancy Leveille in Clinical & Quality, Finance & Reimbursement

There are two compliance certifications due for 2018 by year's end.

Note:  There is a change to OMIG’s compliance certification process, effective December 2018. 

As referenced in OMIG’s 2018-2019 Work Plan, providers subject to the mandatory compliance program obligation are required to complete an annual certification using their Provider Identification Numbers (Provider IDs) rather than their Federal Employer Identification Numbers (FEINs) 

The updated certification form and Frequently Asked Questions document will be available on OMIG’s website on Monday, December 3, 2018. An informational webinar will be posted by the end of the day today at: https://omig.ny.gov/information/webinars . 

Additionally, providers will be notified of these changes via OMIG’s listserv and an article will be included in the November Medicaid Update. 

For those subject to the Deficit Reduction Act of 2005 (DRA), the DRA certification form has not changed. 

Below please find detailed information on both certifications: 

New York State Social Services Law Section 363-d Certification Reminder

All New York State Medicaid providers who are required to have a compliance program under New York State Social Services Law Section 363-d must certify that their compliance programs are effective each year. The certification must be completed during the month of December. The Social Services Law certification is an online certification that can be accessed on OMIG’s website at www.omig.ny.gov (go to bottom of page under Compliance). Frequently asked questions and directions are also located there. Additionally, when you complete the certification, you will receive a confirmation e-mail from OMIG and a confirmation receipt.  We encourage you to print a copy and keep it on file.

Federal Deficit Reduction Act of 2005 Certification Reminder

If you are a NYS Medicaid provider subject to the Federal Deficit Reduction Act of 2005 (DRA), you must provide a certification that you are meeting the DRA’s requirements. The certification must be completed each year prior to January 1st. The DRA certification is an online certification that can be accessed on OMIG’s website at www.omig.ny.gov (go to bottom of page under Compliance). Look for the Certification sub-tab and look for the form under the heading “Federal Deficit Reduction Act.” You will also find frequently asked questions and directions located there. Additionally, when you complete the certification you will receive a confirmation e-mail from OMIG and a confirmation receipt. We encourage you to print a copy and keep it on file. Members should ensure they have a plan in place as they attest to their compliance. DOH has randomly selected SNFs over the past year to test their compliance plans.

Resources

Additionally, on or before December 1, 2018, OMIG will post on its website a webinar that provides information about and guidance on completing the new 2018 certification form. The webinar will be available at: https://www.omig.ny.gov/resources/webinars.

Questions on the December 2018 certification obligation should be directed to OMIG's Bureau of Compliance at(518) 408–0401 or by using the Bureau of Compliance's dedicated e-mail address compliance@omig.ny.gov.

On October 26, 2016, the NYS OMIG published its Compliance Program Review Guidance. The Guidance is available at https://www.omig.ny.gov/images/stories/compliance/compliance_program_review_guidance.pdf

The Guidance describes what OMIG looks for when it conducts compliance program reviews of providers that are subject to the mandatory compliance program requirements established in New York State Social Services Law Section 363-d subsection 2 and Title 18 of the New York Codes of Rules and Regulations at Section 521.3(c). Providers subject to the mandatory compliance program obligation of those sections can refer to the Guidance to identify the types of questions OMIG will ask when it conducts compliance program reviews.

If you have questions about either certification, please send an e-mail to compliance@omig.ny.gov.

NYSHFA CONTACTS:

Nancy Leveille, RN, MS
Executive Director
518-462-4800 x20

Carl J. Pucci
Director, Finance & Reimbursement
518-462-4800 x36