On September 1, 2015, the New York State Office of the Medicaid Inspector General (OMIG) posted DSRIP Compliance Guidance 2015-01 Revised: Special Considerations for Performing Provider System (PPS) Leads’ Compliance Programs replacing the Compliance Guidance initially published on April 6, 2015. The Revised Guidance is intended to highlight special considerations as PPS Leads develop compliance plans.
The DSRIP Compliance Guidance is specific to the Delivery System Reform Incentive Payment (DSRIP) Program mandatory compliance programs that must be in place for PPS Leads. PPS Leads must conform mandatory compliance programs with the obligations set out in New York Social Services Law Section 363-d and 18 New York Code of Rules and Regulations Part 521. The Revised DSRIP Compliance Guidance sets out new considerations that PPS Leads should work into their compliance programs regarding:
- Compliance expectations for DSRIP funds
- Compliance Officer employment and reporting
- Compliance training and education
- Compliance reporting procedures
- Good faith compliance participation
- Identifying compliance risk areas
- Compliance issue response
- Non-intimidation and non-retaliation
The Revised DSRIP Compliance Guidance is available on the OMIG website at: https://www.omig.ny.gov/dsrip-compliance-guidance.
The newly published guidance is limited to this current phase of the DSRIP program. OMIG expects that as the DSRIP program develops, PPS Leads’ compliance programs will adapt to include additional considerations as new Compliance Guidance is published. Barclay Damon will continue to monitor these developments and provide updates regarding future DSRIP Compliance Guidance revisions.