Client Alert: New York State Publishes Proposed New Compliance Program Requirements for Medicaid Providers

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On January 14, 2009, the New York State Office of the Medicaid Inspector General (OMIG) published a proposed rule in the New York State Register governing mandatory compliance programs for Medicaid providers. When finalized, the regulations will implement Section 363-d of the NYS Social Services Law, enacted in 2006, which requires Medicaid providers to develop and implement compliance programs aimed at detecting fraud, waste and abuse. The proposed rule specifies which providers are required to have compliance programs and the components such programs must contain. Comments on the proposed regulations must be submitted to OMIG by February 28, 2009.

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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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