If you are a Chief Compliance Officer or otherwise involved in the management of a Medicaid or Medicare participating provider or health plan, you are acutely aware that the fraud and abuse compliance/enforcement landscape has dramatically changed in the past few years. Key contributors to this “new world” include:
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- the new PPACA provision requiring the reporting and return of overpayments within 60 days;
the changes to the Federal False Claims Act and Civil Monetary Penalties Statute enacted by the Fraud Enforcement and Recovery Act of 2009 (FERA);
- the comparable changes to the New York False Claims Act enacted by the “NY FERA” in 2010;
- the aggressive audit, data mining and recoupment efforts of the New York State Office of the Medicaid Inspector General (OMIG), the New York Attorney General’s Medicaid Fraud Control Unit (MFCU), and the HHS Office of the Inspector General (OIG);
- the advent of various recovery audit contractors (RACs, MICs, ZPICs, PSCs, Medicaid RACs); and
- New York’s mandatory “effective” compliance plan requirements.
Hinman Straub has a team of recognized experts dedicated to assisting both provider and health plan clients to meet the challenges of this rapidly evolving compliance environment. Our fraud and abuse group can provide practical, problem-solving and problem-preventing representation and consultation in each of the following specific areas:
- Responding to OMIG Audits
- Reporting and Return of Overpayments
- Compliance with Self Disclosure Protocols
- Development and Implementation of Effective Compliance Plans
- Identifying High Risk Areas and Self-Auditing