OMIG s Compliance Certification Process for Mandatory Compliance Programs:

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OMIG s Compliance Certification Process for Mandatory Compliance Programs: Enrolling Provider or Revalidating Provider Webinar # 25 January 27, 2015

January 27, 2015 2 Welcome OMIG appreciates your interest in this Webinar

January 27, 2015 3 The Fine Print These slides are not intended to provide legal advice; do not represent the opinion of the Office of the Medicaid Inspector General (OMIG); do not represent the opinion of the Centers for Medicare and Medicaid Services (CMS), the Office of the Inspector General (OIG) or any other state or federal agency; and shall not bind OMIG in any way.

January 27, 2015 4 Goals of this Webinar Introduce the forms that providers must use to meet their New York State Social Services Law Mandatory Compliance Program certification requirement on enrollment and during revalidation of enrollment; and

January 27, 2015 5 Goals of Webinar # 25 (Continued) PLEASE NOTE THAT Webinar # 24 should be consulted for more background on the mandatory compliance obligations. This Webinar will not address the Annual December Certification obligation for the Federal Deficit Reduction Act (DRA) of 2005 or New York State s Mandatory Compliance Programs.

January 27, 2015 6 OMIG AT A GLANCE

January 27, 2015 7 Mission Statement Our mission is to enhance the integrity of the New York State Medicaid program by preventing and detecting fraudulent, abusive, and wasteful practices within the Medicaid program and recovering improperly expended Medicaid funds while promoting high-quality patient care.

January 27, 2015 8 We Have A Statewide Presence Regional Offices: Albany Buffalo Hauppauge New York city Rochester Syracuse White Plains

January 27, 2015 9 NYS Medicaid Mandatory Compliance Program Certification Obligation

January 27, 2015 10 Medicaid Provider Compliance Obligations Mandatory Compliance Program Certification Requirement 18 NYCRR 521.3 (b) Upon applying for enrollment in the medical assistance program, and during the month of December each year thereafter, a required provider shall certify to the department, using a form provided by the Office of the Medicaid Inspector General on its Web site, that a compliance program meeting the requirements of this Part is in place.

January 27, 2015 11 NYS Mandatory Compliance Program Certification Form

January 27, 2015 12 What s Available When Certifying OMIG s certification landing page has links to the forms and to resources. http://www.omig.ny.gov/compliance/certification The Social Services Law (SSL) form has a series of questions to help providers know what is required to be in place in order to certify. Enrollment Categories on the forms will change during the year.

January 27, 2015 13 How Can I Successfully Complete the Certification Process?

January 27, 2015 14 Suggestions for a Successful and Effective Certification Process 1. Identify all Federal Employer Identification Numbers (FEIN) that you are or expect to order, claim, or receive Medicaid payments through. Some providers have multiple FEINs. 2. Certification is required for every FEIN that orders, claims, or receives Medicaid payments; or submits claims on behalf of another for Medicaid services, who are subject to the mandatory compliance program obligation.

January 27, 2015 15 Suggestions for a Successful and Effective Certification Process (Continued) 3. Review your mandatory compliance program to confirm that it meets all eight elements of the NYS Social Services Law and the regulations. 4. Assess whether your mandatory compliance program is implemented and operating. 5. Identify the appropriate person to be the certifying official for the SSL. It should be someone who is familiar with the compliance program (who the compliance function reports to is ideal).

January 27, 2015 16 Suggestions for a Successful and Effective Certification Process (Continued) 6. Make sure that firewalls, filters, and antivirus programs will allow connection and submission. 7. Conduct regular assessments of your compliance program and identify any gaps. 8. Create an annual work plan and assess the progress on prior work plans, as well as the status of plans of correction.

January 27, 2015 17 Suggestions for a Successful and Effective Certification Process (Continued) 9. Interact with the certifying official, senior management, and governing board in addressing the work plan, plans of correction and gaps. 10. If you certify and you cannot locate your confirmation page, do not recertify; instead, request a copy by email to compliance@omig.ny.gov. 11. Sign-up for OMIG s listserv to receive certification reminders.

January 27, 2015 18

January 27, 2015 19 How to Fill Out the Certification Forms Successfully

January 27, 2015 20 Cautionary Points on Certification Do not make false statements on the certification forms. Make sure that your firewalls and security settings will allow for the certification process to be completed. Use the correct form (SSL vs. DRA). Use the correct FEIN(s). Certify for each FEIN in the enterprise involved in Medicaid that has a compliance obligation.

January 27, 2015 21 Consequences for Not Certifying Some of the consequences for failing to certify include: Newly enrolling Medicaid providers may not be able to complete their enrollment process with DOH. Medicaid providers revalidating enrollment with DOH may not be able to smoothly complete the process.

January 27, 2015 22 Questions Questions related to this Webinar or on the Social Services Law Mandatory Compliance Program certification forms should be sent to compliance@omig.ny.gov.

January 27, 2015 23 Compliance Resources Our website: www.omig.ny.gov Compliance Library Compliance Authorities OMIG Compliance Publications Forms OMIG Assessment Results FAQs Compliance-related Webinars Other Compliance Resources

January 27, 2015 24 Compliance Resources (Continued) Bureau of Compliance dedicated email address compliance@omig.ny.gov Bureau of Compliance dedicated telephone number 518.408.0401

January 27, 2015 25 Thank you