OMIG Getting Serious About Compliance Programs


Despite our prior urgings to health care providers (especially nursing homes and home care agencies) to establish "effective compliance plans," that advice has often gone unheeded. Currently, some providers are content to have "paper" compliance plans that are either outdated or poorly implemented – or none at all..

The game has now officially changed. OMIG’s Matt Babcock and his compliance team, headed by Carol Booth, are intending to audit providers’ individual compliance plans – especially providers who were required to have such plans in place as of October 1, 2009. To verify compliance, Ms. Booth and her staff will conduct both announced and unannounced visits. Should you be unlucky enough to be selected for this review, OMIG will ask you to produce a list of documents (see directly below) and make available for interview various employees from the CEO to “randomly identified staff.” These interviews will address, among other things, the employee’s knowledge of the company’s compliance program.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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