Compliance/Enforcement - Identifying High Risk Areas and Conducting Related Internal Audits

New York is one of the few states in the country that requires virtually all Medicaid providers and Medicaid Managed Care Plans to maintain effective compliance plans, and to annually certify their adoption and implementation to the New York State Office of the Medicaid Inspector General (OMIG).

One of the key required elements of a mandatory compliance plan is an internal audit policy that targets identified high risk areas for Medicaid over-billing. An internal audit policy must be kept current to assure that it reflects appropriate high risk areas specific to each type of provider, and should be reviewed at least annually.

Hinman Straub's fraud and abuse group assists clients in all phases of the development and implementation of the internal audit component of their compliance plan. This includes the identification of high risk auditing priorities that are consistent with all relevant enforcement agency guidance as reflected in:

  • OMIG's annual Work Plan;
  • HHS's Office of Inspector General's Work Plan;
  • OMIG/OIG Corporate Integrity Agreements;
  • OMIG's Final Audit Reports;
  • OIG's Special Fraud Alerts;
  • OIG's audit and investigation reports;
  • Medicare and Medicaid Recovery Audit Contractor (RAC) activities;
  • OMIG Compliance Alerts; and
  • The New York Attorney General's Medicaid Fraud Control Unit (MFCU) activity.

Practice Area Professionals

Sean Doolan

Mara Ginsberg

Raymond Kolarsey

Philip Murphy

Stephanie Piel

Jennie Shufelt

To learn more about our Health services, please contact Raymond Kolarsey.