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New York State Office of the Medicaid Inspector General Releases Guidance on Compliance Program Reviews

In the 1990s, as part of the Federal Sentencing Guidelines, the U.S. Sentencing Commission developed for the first time the criteria upon which it will view an organization’s compliance program to be “effective.” In October...more

New York State Requires PBM Contracts to Include a Mechanism for Appealing Disputes Related to Generic Drug Pricing

On December 11, 2015, Senate Bill 3346-B[1] was signed into law by New York State Governor Andrew Cuomo. The new bill requires contracts between pharmacy benefit managers (“PBMs”) and pharmacies (or pharmacies’ contracting...more

New York State OMIG Releases Work Plan for Fiscal Year 2015-2016

On April 1, 2015, the New York State Office of Medicaid Inspector General (“OMIG”) released its Work Plan for fiscal year (“FY”) 2015-2016 (April 1, 2015 – March 31, 2016). The OMIG’s mission is to prevent and detect...more

HEAL Advisory: Recent Decision Casts More Uncertainty Over New York Executive Order 38's Cap on Executive Compensation

With so many questions surrounding the implementation of the New York State ("NYS" or "State") Governor's Executive Order 38 cap on executive compensation (and administrative expenses), most stakeholders expected...more

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