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Friday, September 29, 2023

New York Medicaid Suppliers Now Have Two Pathways to Self-Disclose Overpayments to the Workplace of the Medicaid Inspector Normal


On August 21, 2023, the New York State Workplace of the Medicaid Inspector Normal (OMIG) introduced updates to the Medicaid overpayment self-disclosure program, which now consists of an abbreviated course of for reporting and explaining overpayments which are thought-about routine or transactional in nature and have been already voided and adjusted.

The OMIG self-disclosure course of has lengthy been established to offer an avenue for Medicaid suppliers to report, return and clarify Medicaid overpayments inside 60 days of figuring out the overpayment (or by the date any corresponding value report was due) as is required by each Federal and State legislation.[1]

Suppliers that establish a Medicaid overpayment now have two selections inside the OMIG self-disclosure framework primarily based on the error recognized. Errors that require formal corrective motion plans ought to at all times be self-disclosed utilizing the “Self-Disclosure Full Assertion,” whereas errors which are extra transactional or routine in nature and already repaid by means of voids or changes could also be higher suited to the brand new “Self-Disclosure Abbreviated Assertion.”[2]

For instance, overpayments ensuing from any of the next needs to be self-disclosed utilizing the Self-Disclosure Full Assertion:

  • Any error that requires a Medicaid entity/supplier to create and implement a proper corrective motion plan;
  • Precise, potential or credible allegations of fraudulent habits by staff or others;
  • Discovery of an worker on the “Excluded Supplier” record;[3]
  • Documentation errors that resulted in overpayments;
  • Overpayments that resulted from software program or billing techniques updates;
  • Systemic billing or claiming points;
  • Overpayments that concerned a couple of Medicaid entity/supplier;
  • Non-claim-based Medicaid overpayments;
  • Any error with substantial financial or program impacts; and
  • Any occasion upon path by OMIG.

Examples of overpayments that needs to be self-disclosed utilizing the brand new Self-Disclosure Abbreviated Assertion, embrace:

  • Routine credit score stability/coordination of advantages overpayments;
  • Typographical human errors;
  • Routine Internet Out there Month-to-month Revenue (NAMI) changes (relevant to nursing dwelling residents);
  • Cases of lacking or defective authorization for providers as a result of human error;
  • Cases of lacking or inadequate assist documentation as a result of human error;
  • Inappropriate charges, procedures or charge codes used as a result of typographical or human error; and
  • Routine recipient enrollment points.

OMIG cautions Medicaid suppliers that voiding or adjusting claims with out additionally utilizing the abbreviated self-disclosure course of doesn’t fulfill the supplier’s obligation to report and clarify the recognized overpayment.

In case you have any questions concerning the OMIG self-disclosure course of or want help in processing an OMIG self-disclosure, please attain out to a member of the Sheppard Mullin Healthcare Staff.

FOOTNOTES

[1] See 42 U.S.C. §1320a-7k(d); NY Social Providers Legislation §363-d(6).

[2] The Self-Disclosure Full Assertion and the Self-Disclosure Abbreviated Assertion can be found on OMIG’s web site at: https://omig.ny.gov/self-disclosure-submission-information-and-instructions.

[3] “Excluded Supplier” lists are maintained by each Federal and New York State authorities businesses. The Workplace of Inspector Normal inside the U.S. Division of Well being and Human Providers maintains a “Checklist of Excluded People/Entities”, which is compromised of people and entities which are excluded from collaborating in Federal well being care packages (e.g., Medicare and Medicaid). See https://oig.hhs.gov/exclusions. The OMIG maintains an inventory of Medicaid suppliers who’re not eligible to take part within the Medicaid program. See https://omig.ny.gov/medicaid-fraud/medicaid-exclusions.

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