- August 25, 2023
- Alerts
OMIG Updates Self Disclosure Program With Streamlined Process for Routine Overpayments
By:
David M. Traskey
On August 21, 2023, the New York State Office of the Medicaid Inspector General (OMIG) updated its Self-Disclosure Program to provide a new pathway for all Medicaid-program entities and providers to report, return, and explain overpayments. Specifically, these entities and providers can now use a streamlined “Abbreviated Self-Disclosure Process” for overpayments that are “considered routine or transactional errors in nature or meet other defined characteristics and have already been voided or adjusted” provided that they otherwise satisfy all of the eligibility criteria to participate in the Self-Disclosure Program (emphasis added). This new pathway promises to provide an avenue for entities and providers to report routine overpayments more efficiently without having to do a more extensive disclosure as in the past.
Issues suited for the Abbreviated Self-Disclosure Process include: (1) routine credit balance/coordination of benefits overpayments; (2) typographical human errors; (3) routine net available monthly income (NAMI) adjustments; (4) instances of missing or faulty authorization for services due to human error; (5) instances of missing or insufficient support documentation due to human error; (6) inappropriate rate, procedure of fee code used due to typographical or human error; and (7) routine recipient enrollment issues.
The requirement that entities and providers report, return, and explain overpayments within 60 days of identification, or by the date that any corresponding cost report was due, whichever is later, remains in effect. For issues that are unsuited for the Abbreviated Self-Disclosure Process, entities and providers can continue to submit disclosures by using the original Self-Disclosure Full Statement.
Should you have any questions regarding the above, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at info@garfunkelwild.com.
Issues suited for the Abbreviated Self-Disclosure Process include: (1) routine credit balance/coordination of benefits overpayments; (2) typographical human errors; (3) routine net available monthly income (NAMI) adjustments; (4) instances of missing or faulty authorization for services due to human error; (5) instances of missing or insufficient support documentation due to human error; (6) inappropriate rate, procedure of fee code used due to typographical or human error; and (7) routine recipient enrollment issues.
The requirement that entities and providers report, return, and explain overpayments within 60 days of identification, or by the date that any corresponding cost report was due, whichever is later, remains in effect. For issues that are unsuited for the Abbreviated Self-Disclosure Process, entities and providers can continue to submit disclosures by using the original Self-Disclosure Full Statement.
Should you have any questions regarding the above, please contact the Garfunkel Wild attorney with whom you regularly work, or contact us at info@garfunkelwild.com.