The New York State Office of the Medicaid Inspector General (OMIG) released updated self-disclosure FAQ and guidance documents on January 19. The documents contain several clarifications sought by GNYHA and the Healthcare Association of New York State following our joint briefing with OMIG on October 16 (an online recording is available on the GNYHA website).
Many updates concern OMIG’s new, abbreviated self-disclosure process, including a best practice recommendation for providers to use aggregate monthly reports for claims voided or adjusted in the prior month. Importantly, while OMIG will send a confirmation of receipt to providers upon submission of an abbreviated self-disclosure report, they will not otherwise contact providers unless additional information is needed.
OMIG offers multiple examples of when providers should use the full or abbreviated process, and a listing of repayment options. Any claims reported via the abbreviated process must be voided or adjusted prior to submission. This is also the recommended repayment method for claims reported via the full process. Providers should include the original Transaction Control Number in full and abbreviated reports.
OMIG also noted that Medicaid managed care organizations (MMCOs) must establish their own self-disclosure programs for participating providers and that providers should return managed care overpayments directly to MMCOs. If an MMCO is unresponsive to a provider seeking to report and return an overpayment, the provider should document contact attempts and submit a full self-disclosure report to OMIG.