Thought Leadership presented by Grassi & Co
The experience level and recoupment efforts of the Office of Inspector General (OIG) and Office of the Medicaid Inspector General (OMIG) get better and better. The roles of today’s corporate compliance officer are varied, and many are not familiar with designing and implementing internal controls, or developing policies and procedures that assure compliance with numerous laws.
Items to consider
The New York State OMIG conducted webinars that highlighted the elements of an effective compliance program, and who is required to file the two certifications — the DRA and SSL. Once you have certified to the OMIG that you have an effective program and have updated the OMIG’s assessment tool, here are items you need to consider prior to a review:
- Support for all eight requirements
- An organization chart that indicates the compliance officer and the reporting line
- A new 2016 compliance plan that is prepared and approved by the board
- An annual risk assessment identifying organizational weaknesses which need to be addressed
The BOC letter of invitation requests information that substantiates your claim to having an effective compliance program. Therefore, you will need to provide:
- Minutes of the compliance committee meetings
- Proof of training of board, management, staff and all affected individuals
- Proof of the reviews performed
- Documented specific policies that correlate to the eight requirements
The statement on the certificate form stating, “You may be subject to criminal prosecution for a misdemeanor or felony under NYS Penal law for false statements,” is not to be taken lightly.
The compliance officer has become critical to the continuous operation of the organization. In 2016, organization’s will be required to establish a budget for compliance officers to allocate resources and plan reviews.