The New York State Office of the Medicaid Inspector General (“OMIG”) issued a Listserv Notice on June 26, 2025 advising that its Compliance Program Reviews (“CPRs”) beginning after July 1, 2025, will use a 12-month Review Period for newly initiated CPRs. CPRs are used by OMIG to determine whether Medicaid Providers’ compliance programs have in fact adopted, implemented, and maintained an effective compliance program as required by Title 18 New York Codes, Rules, and Regulations Part 521. OMIG confirms that this change will not affect reviews currently being conducted.
Compliance programs are required to be effective and operating continuously. The Review Period is the time period used by OMIG to determine if Medicaid Providers’ compliance programs are effective. Based on prior OMIG guidance, Review Periods will not exceed 12-months and will be retrospective (i.e., for a period prior to the date of commencement of the CPR).
Since starting CPRs in 2023, OMIG used Review Periods less than 12-months. For example, OMIG used calendar quarters for Review Periods.
The OMIG Listserv Notice can be accessed at this link: https://omig.ny.gov/news/2025/omig-begin-performing-12-month-review-period-compliance-program-reviews
If you require assistance or have questions, please reach out to attorney Stephanie Sobkowiak at (203) 772-7782 and ssobkowiak@harrisbeachmurtha.com; attorney Roy W. Breitenbach at (516) 880-8378 and rbreitenbach@harrisbeachmurtha.com; attorney Nicole Ozminkowski at (585) 419-8602 and nozminkowski@harrisbeachmurtha.com or the Harris Beach Murtha attorney with whom you most frequently work.
This alert is not a substitute for advice of counsel on specific legal issues.
Harris Beach Murtha’s lawyers and consultants practice from offices throughout Connecticut in Bantam, Hartford, New Haven and Stamford; New York state in Albany, Binghamton, Buffalo, Ithaca, New York City, Niagara Falls, Rochester, Saratoga Springs, Syracuse, Long Island and White Plains, as well as in Boston, Massachusetts, and Newark, New Jersey.
