August 22, 2023

Yesterday at 6:29 pm we sent you the updated OMIG Compliance Plan Guidance related to Self-Disclosures. When we reviewed the document, we found insufficient acknowledgment of what we told you last week – that the Governor’s Office had written to us and stated OMIG would make it clear that providers were not going to be held liable for use of previously established self-disclosure practices for overpayments for the period of time before the release of the updated guidance (yesterday).  As such, we went back to OMIG seeking something more concrete.  

Here’s what we received via email today, August 22, from OMIG:
” Providers were appropriate in utilizing the previous established process to identify and report on Medicaid overpayments prior to OMIG’s development and implementation of the Abbreviated Self-Disclosure mechanism. 

To confirm, the option of using this new process is prospective. Therefore, going forward, providers have the option to use the abbreviated process or full process depending on their determination of the circumstances involved based on OMIG’s revised  guidance issued. 

Given this guidance is being released late in the month of August, we do not anticipate many providers will use this new process until September, with the first monthly reporting expected in October. Accordingly, the timeline is outlined in the listserv announcement (copied below). 

OMIG anticipates the first full month of reports to be in September and the first monthly reporting to be October 5.“