The Office of the Medicaid Inspector General (OMIG) recently published guidance affecting compliance program certifications each December. Effective this year, the “Certifying Official,” i.e., the person who submits the required certification on OMIG’s website, cannot be the provider’s Compliance Officer. Rather, the “Certifying Official” must be the person to whom the Compliance Officer reports on the activities of the compliance program. The “Certifying Official” should be either (1) the provider’s chief executive, (2) a senior administrator designated by the chief executive to whom the Compliance Officer reports, or (3) a member of the provider’s governing board to whom the Compliance Officer periodically reports.

Providers should review their internal compliance certification procedures to ensure that an appropriate person within the organization submits the annual certification as the “Certifying Official.” A copy of the recent compliance guidance can be found here.