New Beginnings Home Care, Inc.
Compliance Program
Standards of Conduct
Introduction and Dedication to NBHC, Inc.’s Compliance Program:
New Beginnings Home Care, Inc. is dedicated to maintaining the highest ethical and professional standards possible. We aim to do so through our agencies ongoing education, maintenance and implementation of our compliance program adhering to applicable laws set forth through NYS Office of the Medicaid Inspector General’s statutory regulatory requirements and guidance. Our commitment and dedication is essential to New Beginnings Home Care, Inc. achieving its mission, as a significant percentage of the services we provide are reimbursed through Medicaid funded programs, therefore we require all areas of our agencies business be conducted in an ethical manner with the utmost integrity and accuracy.
Our compliance program has been set forth to ensure that NBHC, Inc.’s day to day operations of our business and is being conducted in compliance with all applicable laws as well as ensuring we uphold the highest ethical standards.
This Compliance Program is intended to prevent both inadvertent and intentional noncompliance with applicable statutory, regulatory and other requirements; to promote the detection of noncompliance if it occurs; to discipline offenders when appropriate; and to educate New Beginnings Home Care, Inc.’s employees on the importance of compliance and NBHC, Inc.’s compliance procedures.
This Compliance Program Standards of Conduct will be reviewed as needed, at a minimum annually, and updated as needed to ensure that NBHC, Inc. maintains the highest possible compliance procedures. NBHC, Inc. recognizes the importance of and is committed to educating its employees on up-to-date compliance standards and procedures.
The Standards of Conduct set forth in this Compliance Program constitute NBHC, Inc.’s policies. Any questions or concerns relating to any compliance related matter should be immediately referred to the NBHC, Inc.’s Chief Compliance Officer.
The Standards of Conduct set forth in this Compliance Program, along with all policies and procedures pertaining to the Compliance Program apply to all affected individuals, i.e. all employees of New Beginnings Home Care, Inc.
Consistent with the Compliance Program, NBHC, Inc. submits claims for services that are actually ordered, coded accurately, and documented with the proper requirements per each Medicaid program. It is the responsibility of every employee of the NBHC, Inc. to be familiar with this Compliance Program and to be sensitive to any situations that may violate it and their obligation to report such violations. Claims of ignorance, good intentions and bad advice are not acceptable as excuses for non-compliance. Those in supervisory positions have the additional responsibility to verify that supervised personnel understand and comply with the standards of professional and business conduct set forth in this Compliance Program.
Purpose:
The purpose of this compliance program is to enable New Beginnings Home Care, Inc.’s ability to demonstrate the businesses integrity and trustworthiness in complying with applicable laws and regulations set forth with the Office of the Inspector General’s Medicaid and Managed Medicaid health care programs.
New Beginnings Home Care, Inc. implemented and will continue to maintain the requirements specified herein to the extent reasonably possible.
New Beginnings Home Care, Inc. and
(a) each of its board members, trustees, directors, officers, and employees;
(b) any individuals engaged directly by New Beginnings Home Care, Inc. to provide patient care services, such as Registered Nurses, Service
Coordinators, Independent Living Skills Trainers, Personal Care Aides, and all other administration professionals;
(c) individuals involved in the management, sales, marketing, and billing process of New Beginnings Home Care, Inc.’s services (whether employees or independent contractors); and
(d) all individuals whom request any of the services provided by the agency shall maintain the business integrity and honesty required of a participant-supplier in all Medicaid or Managed Medicaid funded programs.
Confidentiality:
All New Beginnings Home Care, Inc. employees possess sensitive, privileged information about clients and their care. Clients properly expect that this information will be kept confidential. NBHC, INC. takes any violation of their confidentiality, seriously. Discussing any client’s medical
condition or providing any information about them to anyone other than NBHC, Inc.’s personnel whom require the information or other authorized persons will result in disciplinary action and possible termination. Employees are not to discuss clients outside of NBHC, Inc.
NBHC, Inc. is required to maintain the confidentiality of each client’s medical record. In this regard, medical records may not be released except with the written authorized consent of the client or in other limited circumstances as required by law. Special confidentiality requirements apply
with regard to medical records relating to HIV infection and AIDS. Medical records should not be physically removed from NBHC, Inc’s property, altered or destroyed. Employees who have access to medical records must exercise their best efforts to preserve their confidentiality and integrity and no employee is permitted access to the medical record of any client without a legitimate reason and with the proper authorization for doing so. If a question arises as to the permissibility of the release of a client’s medical record or any information contained therein, the employee should seek
guidance from the employee’s supervisor, the Director of Nursing or the Compliance Officer.
NBHC, Inc. employees must comply with applicable regulations set forth in the Health Insurance Portability and Accountability Act (HIPAA). Additionally, employees are to treat as confidential NBHC, Inc.’s proprietary business assets including: valuable ideas, business plans, and other
information about NBHC, Inc.’s business.
NBHC, INC. ’s employees should respect NBHC, Inc.’s assets as they would their own. No employee shall divulge to unauthorized persons, either during or after their employment, any information of a confidential nature connected with the business of NBHC, Inc.
All New Beginnings Home Care, Inc. employees are protected under the Whistleblower Protection Act. This act states that an employer cannot retaliate by taking “adverse action” against workers who report injuries, safety concerns or in this case, any compliance issues including but not limited to fraud, misuse of services, etc. This act protects individuals who reports violations of various workplace issues.
The Compliance Officer:
The Compliance Officer’s duties as an employee of New Beginnings Home Care, Inc. ensures the day-to-day operation of the compliance program. These duties include, but are not limited to the ongoing monitoring, evaluation, and implementation of NBHC, Inc.’s standards, policies, procedures, administration, maintenance, education and training, employee screenings and evaluations, auditing, reporting systems, direct lines of communication including the receiving, generating and presenting reported outcomes processes, investigation processes and to respond in an ethical manner regarding the implementation of the agencies policies and procedures of the Compliance Program.
Please direct any questions, comments or concerns to the Compliance Officer ~
Sabrina O’Hare
New Beginnings Home Care, Inc.
12-14 East Garden Street
Auburn, NY 13021
Phone: 315.255.3390 Ext. 314
Fax: 315.255.2390
The Roles and Responsibilities of the Compliance Officer shall include (but not limited to):
1. Overseeing and monitoring the implementation of the compliance program and reporting on a regular basis to the Chief Executive Officer and the Compliance Committee on the progress of implementation;
2. Assisting in establishing methods to improve the New Beginnings Home Care, Inc.’s efficiency and quality of services and to reduce the New Beginnings Home Care, Inc.’s vulnerability to fraud, abuse and waste;
3. Periodically revising the compliance program to conform to changes in the organization, the law, and policies and procedures of government and private pay health plans;
4. Reviewing employees’ certifications that they have received, read and understood the standards of conduct;
5. Developing written compliance policies and procedures that are readily understandable by all employees;
6. Coordinating and participating in a multifaceted education and training program that focuses on the elements of the compliance program and seeks to ensure that all appropriate employees and management know, and comply with, pertinent federal, state and private payor standards;
7. Ensuring that independent contractors and agents who furnish nursing or other health care services to the clients of the New Beginnings Home Care, Inc., or who provide billing services to the New Beginnings Home Care, Inc., are informed of the New Beginnings Home Care, Inc. ‘s standards of conduct with respect to coding, billing, and marketing, among other things;
8. Coordinating personnel issues with the New Beginnings Home Care, Inc. ‘s Human Resources/Personnel Office to ensure that the National Practitioner Data Bank and Cumulative Sanction Report have been checked with respect to all employees, medical staff, and independent contractors who order or provide services to home health patients;
9. Assisting financial management in coordinating internal compliance review and monitoring activities, including annual or periodic reviews of departments;
10. Independently investigating and acting on matters related to compliance, including the design and coordination of internal investigations (e.g., responding to reports of problems or suspected violations) and any resulting corrective action and reporting thereon to the Corporate Compliance Committee and the Chief Executive Officer; developing policies and programs that encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation;
11. Continuing the momentum of the compliance program and the accomplishment of its objectives long after the initial years of implementation.
12. The Compliance Officer shall have the authority to review all documents and other information relevant to compliance activities, including, but not limited to, patient records, billing records, and records concerning the marketing efforts of the facility and the New Beginnings Home Care, Inc. ‘s arrangements with other parties, including employees, professionals on staff, relevant independent contractors, suppliers, agents, supplemental staffing entities, and physicians.
13. The Compliance Officer shall have the authority to consult with legal counsel when necessary.
Standard Code of Conduct:
It is the policy of the New Beginnings Home Care, Inc. to use its best efforts to avoid fraud, waste and abuse and to adhere to all guidelines and regulations governing federally and state funded health care programs. Policies outlining standards of conduct shall be distributed to all individuals who are affected by the specific policy at issue, along with new and amended or revised compliance policies at time of hire and annually thereafter.
All employee’s actions and conduct will be important factors in evaluating their judgment and competence and an important element in the evaluation of an employee. Employees who ignore or disregard the principles of this code will be subject to appropriate disciplinary actions.
Business Ethics:
1. No Governing Board Member, Employee, may make improper use of the New Beginnings Home Care, Inc. property or permit others to do so. Examples of improper use include the unauthorized appropriation or personal use of services, equipment, technology and patents, software, and computer and copying equipment and the alteration, destruction or disclosure of data.
2. The occasional use of telephones, copying machines and office supplies, when the cost is insignificant, is permitted.
3. Seeking, accepting, offering or making any payment, gift or other thing of value to or from any subcontractor, vendor, supplier or potential contractor for the purpose of obtaining or acknowledging favorable treatment under a private or government contract or subcontract is strictly forbidden.
4. Any contract or other financial arrangement with a physician or other health care provider who is in a position to refer patients to the New Beginnings Home Care, Inc. shall be in writing, shall conform to the New Beginnings Home Care, Inc. ‘s Standards of Conduct.
5. No gifts, free services, or other incentives shall be offered to patients, relatives of patients, physicians, hospitals, contractors, nursing home facilities, or other individuals or entities who would be in a position to refer patients to the New Beginnings Home Care, Inc.
6. All entries on books and records, including financial records, clinical records, and expense accounts, shall be accurate and complete and conform with applicable policies.
7. Employees shall use their best efforts to avoid violations of federal copyright laws, including, but not limited to laws, pertaining to, computer software.
8. Required time records shall be completed in a timely and accurate manner. No cost should be allocated which is unallowable, misallocated, contrary to a contract provision, or otherwise improper.
9. All Governing Board members, managers and employees shall refrain from any conduct during the performance of their duties that has the appearance of impropriety or that could reasonably be construed as contrary to the interests and mission of New Beginnings Home Care, Inc.
Education and Training:
Education and training are critical elements of the Corporate Compliance Program. All employees shall be required to attend training regarding corporate compliance annually. Employees shall receive such training when they are first hired, on a periodic basis thereafter as needed, and annually at minimum. Attendance at such training sessions is a condition of continued employment and adherence to the provisions of the compliance program, including training requirements, shall be a factor in the annual evaluation of each employee. Any formal training undertaken as part of the compliance program shall be documented by the Compliance Officer.
Such training shall emphasize the New Beginnings Home Care, Inc. ‘s commitment to compliance with federal and state statutes, regulations, program requirements, the policies of private payors and corporate ethics. It shall highlight the elements of the compliance program, including how to report suspected violations, summarize the fraud and abuse laws, and review coding requirements, claim development, the claim submission process and marketing New Beginnings Home Care, Inc. s that reflect current legal and program standards.
Basic Compliance Training:
NBHC, Inc. will provide compliance training to all employees and members of the governing authority. This training will be provided under the direction of the Chief Compliance Officer. All new personnel will receive training regarding the Compliance Program as part of the orientation process. Ongoing training will also be provided with respect to changes in the Compliance Program and new legal and/or regulatory requirements. Training will also focus on targeted risk areas as identified by NBHC, Inc. This training will emphasize the importance of compliance practices, which are essential to the operation of NBHC, Inc.
All employees will be educated as to their role in the Compliance Program and the consequences of noncompliance. All compliance training will be documented.
Basic training for appropriate corporate officers, managers and other employees shall include at least the following topics at the time of hire and annually thereafter:
1. Government and private payor reimbursement principles;
2. General prohibitions on paying or receiving remuneration to induce referrals;
3. Improper alterations to clinical records;
4. The need for proper physician authorizations, training/s and certification/s;
5. The need for accurate and timely documentation of services rendered;
6. Patient rights and patient education;
7. Compliance with Medicaid conditions of participation; and
8. The duty to report misconduct and methods of reporting.
Targeted Training:
Targeted training shall be provided to corporate officers, managers and other employees whose actions affect the accuracy of the claims submitted to government and private payors, such as employees involved in the coding and billing reporting processes. Training is required at the time of hire and at a minimum of annually thereafter unless deficiencies in any area is a reported concern.
Supervisors and managers involved in the claims and cost report development and submission processes shall inform all supervised employees and relevant contractors of the following:
1. The compliance policies and legal requirements pertinent to their function;
2. That strict compliance with these policies and requirements is a condition of employment; and
3. The New Beginnings Home Care, Inc. will take disciplinary action up to and including termination for violation of these policies or requirements.
Managers shall assist the Compliance Officer in identifying areas that require training and in carrying out the training as required. Managers and supervisors will be sanctioned for failing to adequately instruct their subordinates for failing to detect noncompliance with applicable policies and legal requirements where reasonable diligence on the part of the manager had been given the opportunity to correct any errors through providing
proper training regarding the applicable policies and legal requirements.
Active clinical/field staff providing any billable service shall participate in educational programs focusing on billing and the need for thorough, precise and timely documentation of services.
The Compliance Officer shall maintain records of employee training, including attendance logs and material distributed at training sessions.
The Compliance Officer shall establish a procedure for employees and others to submit questions about, or request clarification of, any compliance issues. If appropriate, the Compliance Officer shall share the questions and answers with appropriate employees, directors, medical staff appointees and others.
Claim Development and Submission Process:
It shall be the policy of the New Beginnings Home Care, Inc. to:
1. Prior to billing, provide for sufficient and timely documentation of all personal care services, including subcontracted services, to ensure that only
accurate and properly documented services are billed.
2. Emphasize that a claim should be submitted only when appropriate documentation is maintained, appropriately organized in legible form, and
available for audit and review.
3. Provide that the compensation for billing department personnel and billing consultants should not offer any financial incentive to submit claims
regardless of whether they meet applicable coverage criteria for reimbursement or accurately represent the services rendered.
4. Establish and maintain a process for pre-and post-submission review of claims to ensure that claims submitted for reimbursement accurately represent medically necessary services actually provided, supported by sufficient documentation, and in conformity with any applicable coverage criteria for reimbursement.
5. Submission of claims for payment to Medicaid and any other federal or state health insurance programs will be in accordance with current reimbursement policies, regulations and procedures disseminated by the NYS Office of the Medicaid Inspector General, any applicable fiscal in- between or other agency with responsibility for the program in question.
6. Claims for payment shall be submitted to Medicaid or any other Managed Medicaid Insurance companies’ program only for medically necessary that were actually rendered by qualified personnel. Only one bill shall be submitted for each service provided.
7. Claims will be only be submitted when the appropriate documentation supports the claim/s and only when such documentation is maintained for
audit and review. Such documentation shall include at least a properly certified plan of care. Documentation shall include the length of time spent
with each patient, identity and required certification/s of the individual providing the service. The documentation used as the basis for claims
submission shall be organized in a legible form to enable audit and review.
8. All services rendered to patients shall be documented in a proper and timely manner so that only accurate and properly documented services are billed. All RN’s, Service Coordinators, Independent Living Skills Trainers and Personal Care Aides employees shall use their best efforts to communicate effectively and accurately with each other to assure compliance.
9. Compensation for billing department personnel including any outside entity used as the agencies billing consultant/s shall not contain any financial incentive to submit improper claims or codes on behalf of the agency.
10. All services reported on the claim shall be based on the patient’s/participant’s medical chart, approved service plans and any other applicable
documentation, and shall comply with all applicable official coding rules and guidelines. The documentation necessary for accurate code assignment shall be available to the billing departments personnel. New Beginnings Home Care, Inc. ‘s revenue codes used by the billing shall accurately describe the service that was performed by the New Beginnings Home Care, Inc employees.
11. Previously submitted claims shall be randomly examined for accuracy and ensure they are compliant with applicable rules and regulations.
12. The Compliance Officer shall inform the billing department of any steps taken to monitor the New Beginnings Home Care, Inc. ‘s claim submission process.
13. The billing department personnel shall be promptly advised of any incorrectly submitted claim and the billing department personnel shall promptly reimburse Medicaid or any other Managed Medicaid Insurance company for any overpayment.
Identifying Potential Risk Areas:
Note; this list is not all-inclusive list of potential areas of noncompliance, however the areas listed below, require employees to pay close attention to detail.
1. Billing for items or services not actually rendered
2. Billing for services authorized by a physician who has been excluded from the Medicaid program and/or whose state license is not current as evidenced on the NYS Board of Education website.
3.Duplicate billing:
A. Knowingly billing for inadequate care
B. Billing for services provided by unqualified or whom lack proper training to provide the service
C. Inaccurate or incomplete financial reports
D. Licensed Home Care Services Agencies (“LHCSA”) incentive to actual or potential referral sources
E. Anti-kickback statute (42 U.S.C. 1320-a-76)
Additional Compliance Risk Areas: (18 NYCRR 521.3)
A. Medicaid Billings
B. Medicaid Payments
C. The medical necessity and quality of care of the services provided to Medicaid program enrollees;
D. Governance of the Required Provider, particularly as related to the Medicaid program;
E. Mandatory reporting requirements as related to the Medicaid program
F. Credentialing for those who are providing covered services under the Medicaid program;
G. Contractor, subcontractor, agent or independent contract oversight;
H. Other risk areas that are or should with due diligence be identified by the Required Provider; and
I. Additional risk areas for Medicaid Managed Care Organizations (MMCO): Compliance with terms of MMCO’s contract, cost reporting, submission of encounter data to the department, network adequacy and contracting, provider and subcontractor oversight, underutilization, marketing, provisions of medically necessary services, payments and claim processing, statistically valid service verification.
Auditing and Ongoing Monitoring:
Regular and periodic audits of New Beginnings Home Care, Inc. operations will be conducted under the direction of the Compliance Officer, with particular attention paid to the New Beginnings Home Care, Inc. ‘s compliance with laws governing kickback arrangements, claim development and submission, reimbursement, marketing, cost reporting and record-keeping.
Such audits shall also review specific policies and procedures that have been the focus of attention under OMIG’s current annual work plan as guidance.
Audits shall be conducted by individuals who are independent of line management and who have access to existing audit resources, relevant personnel and all relevant areas of operation.
Audit reviews are conducted quarterly. During this review, a set of random files are pulled for audits. The compliance officer produces an error % of non-compliant files. The compliance officer will work with the department to identify the appropriate monitoring and auditing processes so future errors do not occur with the same processes.
Audit procedures shall include, at a minimum:
1. Visits and interviews of patients in their homes;
2. Analysis of utilization patterns;
3. Testing clinical and billing staff on their knowledge of reimbursement coverage criteria and official coding guidelines (e.g., present hypothetical scenarios of situations experienced in daily New Beginnings Home Care, Inc. and assess responses);
4. Assessment of existing relationships with physicians, hospitals, and other potential referral sources;
5. Unannounced mock surveys, audits, and investigations;
6. Reevaluation of deficiencies cited in past surveys for Medicaid conditions of participation;
7. Examination of complaint logs;
8. Checking personnel records to determine whether any individuals who have been reprimanded for compliance issues in the past are among those currently engaged in improper conduct;
9. Interviews with personnel involved in management, operations, claim development and submission, patient care, and other related activities;
10. Questionnaires developed to solicit impressions of a broad cross-section of the New Beginnings Home Care, Inc. ‘s employees and staff;
11. Interviews with physicians who order services provided by the New Beginnings Home Care, Inc.;
12. Reviews of clinical documentation (e.g., plan of care, nursing notes, etc.), financial records, and other source documents that support claims for
reimbursement and Medicare cost reports;
13. Validation of qualifications of physicians who order services provided by the New Beginnings Home Care, Inc.;
14. Evaluation of written materials and documentation outlining the New Beginnings Home Care, Inc. ‘s policies and procedures; and
15. Trend analyses, or longitudinal studies that uncover deviations, positive or negative, in specific areas over a given period.
Violations and Investigations:
1. Any report or evidence of a suspected violation of law, regulations or applicable standards of conduct shall be forwarded to the Compliance Officer who shall review the report or evidence and determine whether there is any basis to suspect that a violation has occurred.
2. If the Compliance Officer determines that a violation may have occurred, the matter shall be referred to outside legal counsel who, with the assistance of the Compliance Officer, shall conduct a more detailed investigation which may include, but is not limited to, the following:
• interviews with individuals who have knowledge of the facts alleged;
• a review of documents;
• legal research and contact with governmental agencies for the purpose of clarification.
3. A log shall be kept of all reports of possible misconduct that indicates the nature of any investigation and its results.
4. Any reports to an outside agency shall be made pursuant to New Beginnings Home Care, Inc. ‘s policy on reporting to outside agencies.
Investigator reviews all necessary documents to assure accuracy for quality reporting while maintaining an unbiased view point to ensure every investigation’s outcome whether it be substantiated or unsubstantiated is solely based on the accuracy of the information collectively gathered throughout the investigation. Upon gathering all of the information, the investigator thoroughly reads, reviews and compares each of the
documents gathered including but not limited to all statements provided to the investigator, which will almost always include a statement from the affected individuals.
Open Lines of Communication:
An open line of communication between the Compliance Officer and New Beginnings Home Care, Inc. employees will be maintained. Any employee or agent who has knowledge of activities that he or she believes may violate the law has an obligation, promptly after learning of such activities, to report the matter to his or her immediate supervisor, to the Compliance Officer or to the Chief Executive Officer. Reports may be made anonymously and without fear of retribution. Every effort will be made to keep reports confidential and the person’s identity will be kept confidential unless the matter is turned over to law enforcement, or disclosure is required during a legal proceeding. The process for reporting suspected violations to the Compliance Officer will be part of the education and/or orientation for all employees.
Employees may seek clarification from the Compliance Officer or the Compliance Committee of any policy or procedure. Requests for clarification and answers shall be documented, dated and, if appropriate, shared with other employees.
Employees will be asked during annual performance reviews and during exit interviews whether they are aware of any potential misconduct or suspected violations of New Beginnings Home Care, Inc. policies and procedures or federal or state laws or regulations.
Compliance Committee:
The Compliance Committee shall be appointed by the Chief Executive Officer and shall consist of the Compliance Officer, who shall serve as its Chairperson, the Medical Director and such other individuals appointed by the Chief Executive Officer.
Compliance Committee’s Functions (but not limited to):
1. Analyzing the regulatory environment, the legal requirements with which the New Beginnings Home Care, Inc. must comply and specific risk areas;
2. Assessing existing policies and procedures that address these areas for possible incorporation in the compliance program;
3. Developing standards of conduct and policies and procedures to promote compliance;
4. Recommending and monitoring the development of internal systems and controls to implement the New Beginnings Home Care, Inc. ‘s standards,
policies and procedures as part of its daily operations;
5. Determining the appropriate strategy/approach to promote compliance and detect potential violations;
6. Developing a system to solicit, evaluate and respond to complaints and problems; and
7. Monitoring internal and external audits and investigations for the purpose of identifying troublesome issues and deficient areas experienced by the New Beginnings Home Care, Inc. and implementing corrective and preventive
action.
Reports to Compliance Committee:
A written report on compliance activities shall be presented to the Compliance Committee, the Chief Executive Officer, and the governing body at a minimum of biannual basis. The report shall identify areas where corrective actions are needed and shall be used by the Compliance Officer and management to correct problems and prevent them from recurring. Subsequent audits will be performed to ensure that corrective
actions have been implemented and are successful.
Disciplinary Actions:
Affected Individuals who fail to comply with the New Beginnings Home Care, Inc. ‘s compliance policies and/or federal or state laws or who have otherwise engaged in wrongdoing that have the potential of impairing the New Beginnings Home Care, Inc. ‘s status as a reliable, honest, trustworthy provider will be subject to discipline in accordance with applicable personnel procedures, which include disciplinary action and
possible termination.
New Beginnings Home Care, Inc. will enforce its disciplinary action standards fairly and consistently with the same disciplinary action applied to all levels of personnel.
Failure to report known violations, failure to detect violations due to negligence or reckless conduct and making false reports shall be grounds for disciplinary action, including termination.
Compliance as an Element of a Performance Plan:
This Compliance Program requires that adherence to the plan shall be a factor in evaluating employee performance. The Compliance Program also serves as a resource and training guide for staff and governs conduct of daily operations. As such, in addition to specific policies and procedures, the Compliance Program also contains the following relevant guidance and instruction regarding key compliance issues:
• All OMIG information published for provider compliance and guidance
• OMIG Special Fraud Alerts;
• OMIG Advisory Opinions
Revised/Reviewed: March 2011, February 2012, February 2013, June 2014, October 2015, October 2016, December 2016, February 2017, February 2018, February 2019, January 2020, January 2021, January 2022, March 2023