Effective July 1, 2025, the New York State Office of the Medicaid Inspector General (OMIG) expanded the review period for newly initiated Compliance Program Reviews (CPRs) from three months—the timeframe used since the inception of the review program—to 12 months. CPRs are conducted to assess whether required providers have adopted, implemented, and maintained an effective compliance program in accordance with 18 NYCRR Part 521.
This change applies only to reviews initiated on or after July 1, 2025, and does not impact CPRs that are already in progress.
Under the revised process, OMIG will issue a written notice to initiate each review and outline procedural steps. Providers will have 30 days from the receipt of the notice to submit a completed CPR Module, along with supporting documentation. OMIG will maintain ongoing communication with providers throughout the course of the review and will issue formal written notification of the results upon completion. Providers are reminded that the best way to prepare for these reviews is to conduct a self-assessment of its plan and implementation, using the OMIG Compliance Program Self-Assessment form, to identify any gaps in compliance or areas for improvement and make those changes prior to any outside review.
Failure to maintain a satisfactory compliance program in accordance with OMIG standards may result in a range of sanctions and penalties under federal and state laws, including the possible revocation of a provider’s Medicaid participating agreement. In addition, OMIG may impose monetary penalties for noncompliance: up to $5,000 per calendar month for an initial failure to implement an effective compliance program and up to $10,000 per month for subsequent failures. These measures underscore the importance of proactive compliance efforts and highlight the serious consequences of noncompliance with program requirements.
Additional details about the CPR process are available on OMIG’s Compliance web page. Guidance regarding potential penalties for noncompliance is available on OMIG’s Compliance Program Guidance Library.
Attorneys on Barclay Damon’s Health Care Controversies and Health & Human Services Providers Teams routinely assist providers with OMIG audits and CPRs and are available to provide guidance and support throughout the review process. Additionally, our attorneys have assisted numerous providers with their internal self-assessments and OMIG CPRs. Please contact us should you have any questions.
If you have any questions regarding the content of this alert, please contact Tricia Lu, associate, at tlu@barclaydamon.com; Melissa Zambri, Health & Human Services Providers Team co-leader, at mzambri@barclaydamon.com; Linda Clark, Health Care Controversies Team co-leader, at lclark@barclaydamon.com; or another member of the firm’s Health & Human Services Providers or Health Care Controversies Teams.