It is axiomatic that New York State requires every Medicaid provider to have an “effective” compliance program. New York Social Services Law § 363-d. In July 2022, the New York State Office of the Medicaid Inspector General (“OMIG”) proposed extensive modifications to the regulatory requirements governing compliance programs for entities receiving “significant” Medicaid revenue (increased by these regulations from a threshold of $500,000 to $1 million). These regulations were proposed to implement portions of the New York State 2020-2021 Budget Bill ...
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