Self- Disclosure Program

Medicaid entities/Providers are required to report, return, and explain any overpayments they have  received to the New York State Office of the Medicaid Inspector General (OMIG) Self- Disclosure Program within sixty (60) days of identification, or by the date any corresponding cost report was due, whichever is later. See Social Services Law (SOS) § 363-d(6).

Identification

Pursuant to SOS § 363-d (6)(b), an overpayment has been identified when a Medicaid entity/Provider has, or should have, through the exercise of reasonable diligence, determined that a Medicaid fund overpayment was received, and they have quantified the amount of the overpayment.

Medicaid entities/Providers who have a compliance program should be utilizing routine internal audits to review compliance with Medicaid requirements and identify any Medicaid fund overpayments that may have been received. Additionally, if a Medicaid entity/Provider is the subject of a government audit, part of that Medicaid entity’s/Provider’s due diligence is to review the results of the audit and look at past and future periods - not covered in the audit scope - to identify any overpayments resulting from similar issues. If overpayments exist, Medicaid entities/Providers are obligated to take corrective action, which includes reporting and returning any Medicaid overpayment identified to OMIG’s Self-Disclosure Program.

Please Note:  Voiding or adjusting claims does not satisfy the Medicaid entity’s/Provider’s obligation to report and explain the identified overpayment.

Timeframes

While both Federal and State regulations require a Medicaid entity/Provider to report, return, and explain an overpayment within sixty (60) days from identification, the actual timeframes for processing can vary. A Medicaid entity’s/Provider’s 60-day time frame will be tolled, or paused, when a completed Self-Disclosure Full Statement is received from an eligible Medicaid entity/Provider. The time frame to repay will remain tolled during OMIG’s review.

More Information

Visit the New York State Office of the Medicaid Inspector General’s Website

Self-Disclosure | Office of the Medicaid Inspector General (ny.gov)

Other Disclosures

Pursuant to Title 18 of the New York Codes Rules and Regulations, Section 504.3, providers are required to prepare and maintain contemporaneous records demonstrating their right to receive payment under the medical assistance program and furnish the records, upon request. If a provider becomes aware that their records have been damaged, lost or destroyed they are required to report that information

to the Self-Disclosure Program as soon as practicable, but no later than thirty (30) calendar days after discovery.

Submission Process

Step 1

Timely report any Medicaid overpayments to the New York State Office of the Medicaid Inspector General (OMIG) via two pathways, full process, or abbreviated process, both of which are located at the link below.

Self-Disclosure Submission Information and Instructions | Office of the Medicaid Inspector General (ny.gov)

Timely report damaged, lost and/ or destroyed records to the New York State Office of the Medicaid Inspector General (OMIG) via the submission of a complete Statement of Damaged, Lost or Destroyed Records and Certification, both of which are located at the link below.

Self-Disclosure Submission Information and Instructions | Office of the Medicaid Inspector General (ny.gov)

Step 2

Damaged/ Lost/ Destroyed Records

  • Notify Molina Healthcare’s Compliance Department via email MNY.Compliance@molinahealthcare.com
    • Subject Line: Damaged/ Lost/ Destroyed Records <Insert Entity Name>
    • Body of the Email: include all details provided to the New York State Office of the Medicaid Inspector General
  • A member of the Compliance Department will respond directly to you for next steps
  • If this is not applicable to your situation, skip to Step 3

 

Step 3

Self-Disclosures

  • Complete Molina’s “Provider Early Reversal Permission Form”
    • In the Comments please indicate “Self-Disclosure as reported to the New York State Office of the Medicaid Inspector General”
  • Fax and/ or mail the completed form and refund to Molina Healthcare’s lockbox for processing (fax/ mail information is located within the form)
  • Notify Molina Healthcare’s Compliance Department of the Medicaid overpayment
    • Subject Line: Self-Disclosure <Insert Entity Name>
    • Body of the Email: confirm you have completed the steps outlined above
  • A member of the Compliance Department will respond directly to you