The New York State Office of the Medicaid Inspector General (“OMIG”) recently released its Compliance Program Guidance for General Hospitals.   While the OMIG had previously released a Compliance Program Assessment Tool, the new Guidance document provides a far greater level of detail as to the expectations of a hospital’s compliance program.

New York State

The 2010 Patient Protection and Affordable Care Act (“PPACA”) imposed an obligation upon Medicare providers, including physicians, hospitals, nursing homes and home health agencies, to report and return any overpayments they receive within 60 days of identification of the overpayment.  Failure to do so could result in substantial penalties to the provider under the False