Last year, as part of the 2020-2021 budget, the New York State Legislature made significant changes to the NYS Mandatory Compliance Program requirement.
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Beginning with dates of services of January 1, 2020, all non-exempt New York State Medicaid payments to providers will be uniformly reduced by 1%. New York State Office of the Medicaid Inspector General (OMIG) annual 2018-2019 Work Plan highlights three areas of concern for the agency: (1) provider compliance; (2) identifying and addressing fraud, waste and abuse in the program; and (3) improving methods of detecting fraudulent activities. The Bureau of Compliance (BOC) within the New York State Office of the Medicaid Inspector General (OMIG) recently performed an assessment of providers’ compliance programs. The results indicate that providers sometimes fail in relatively less complicated and readily addressable ways. The New York State Office of the Medicaid Inspector General (OMIG or agency) has recently issued its 2017-2018 Workplan. The Workplan identifies key areas of OMIG’s focus impacting health care providers and suppliers. The Centers for Medicare & Medicaid Services (CMS) has once again proposed new rules which would enhance the screening requirements for providers and suppliers. The rule proposals would ratchet up the scrutiny on provider enrollments and toughen suspension and revocation penalties. Recent changes to the New York State Medicaid Program affect vaccine administration for pharmacies, claiming process for nurse practitioners, documentation requirements for transportation providers, and prior authorization for physical and occupational therapists. We summarize these changes. Mandatory Electronic Prescribing Effective in NY. While the mandatory electronic prescribing was extended by Gov. Cuomo until March 27, 2016, e-prescribing for controlled and non-controlled substances is already available in New York for those meeting the regulatory requirements. Since 2011, NYS Medicaid Electronic Health Records Incentive Program has paid over $660 million in incentive funds New York State Medicaid has a new vendor to implement the new Medicaid Management Information System (MMIS) that will eventually replace the current vendor (eMedNY). The new vendor, Xerox State Healthcare LLC, won a five year contract with the State. Implementation of the new system will occur in two phases over an eighteen month period. New York Office of the Medicaid Inspector General’s (OMIG) 2013 annual report provides an important insight into the agency’s activities, recoveries and where it plans to focus its resources in the upcoming year. New York State Department of Health (DOH) recently issued a clarification concerning certain pharmacy claims that were rejected because the ordering/prescribing/referring/attending (OPRA) provider was an unlicensed resident, intern or a foreign physicians in training programs. It’s that time of the year when qualifying providers enrolled with the NYS Medicaid Program must certify that they have a adopted, implemented and maintained an effective mandatory compliance program. The NYS Office of the Medicaid Inspector General (OMIG) is tasked with responsibility of overseeing that providers meet this requirement. Can a provider bill a beneficiary all or part of the difference between the provider’s charged fees and the payment received from NJ Medicaid or managed care plan? The NJ Department of Human Services, Division of Medical Assistance & Health Services (Department) recently answered that question. The NYS Medicaid recently informed referring and servicing providers that, effective for services provided on and after October 1, 2013, claims will be denied if they include the NPI of non-enrolled ordering, prescribing, referring or attending provider (OPRA). Below we discuss some of the changes. New York State Medicaid Program posted new applications on April 1, 2013 for non-billing providers that order, prescribe, and/or refer beneficiaries with fee-for-service Medicaid coverage. New Jersey Medicaid required all such providers to be enrolled an “non-billing” providers by Jan. 1, 2013. Most providers know that fees paid by the New York State Medicaid program are considered to be payment in full. This means that as a requirement of participating with Medicaid, and with the exception of co-payments, providers may not bill Medicaid beneficiaries for covered services. Providers may, however, enter into private pay agreement with Medicaid beneficiaries and the article below addresses certain important aspects of that relationship. In the winding days of 2012, the New York State Medicaid announced code changes for physicians and nurse practitioners as well as code changes and changes to the policy manual for New York dentists participating in the Medicaid program. We discuss some of those changes in this article. Recently the New York. State Medicaid Program published an updated version of the Dental Manual as well as the fee schedule. We highlight some of those changes below and encourage all dental providers to analyze the revised documents. This is the third and final article in the series evaluating the NYS Medicaid Compliance Program requirements. The previous two articles looked at those providers required to have a compliance program under the law and the annual certification requirement. In this article, we examine the core elements of a compliance program. This is our second article in a series discussing the New York State Medicaid’s compliance program requirements. In our first article we focused on which providers are required by law to have a compliance program. In this article, we turn our attention to the annual certification requirement. |
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