Health Law Blog

Attention DSRIP Performing Provider System Leads: OMIG Highlights Special Considerations for Compliance Plans

The New York State Office of the Medicaid Inspector General (“OMIG) has released Compliance Guidance for use by DSRIP (Delivery System Reform Incentive Payment)  Performing Provider System (“PPS) Leads who are in the process of developing and implementing a compliance program.  The document highlights special considerations PPS Leads should contemplate for each of the eight core elements that are required components of a compliance plan. 

Generally, OMIG recommends that PPS Leads “follow the money when developing a compliance plan in order to identify and prevent Medicaid payment discrepancies related to DSRIP Program payments. PPS Leads are encouraged to “dedicate resources and develop systems to take all reasonable steps to ensure the Medicaid funds distributed as part of the DSRIP program are not connected with fraud, waste or abuse.

This Compliance Guidance only pertains to the current phase of the DSRIP Program as of the date of the guidance document’s publication.  As the DSRIP Program continues to evolve over time, OMIG expects PPS Leads’ compliance programs to include additional considerations.

For more information, please contact David R. Ross, who served as Acting New York State Medicaid Inspector General under governors Pataki and Spitzer, as well as General Counsel, Deputy Medicaid Inspector General, and Director of Audits and Investigations for the Office of the Medicaid Inspector General.  Prior to his service at the OMIG, David held several positions at the New York State Office of Alcoholism and Substance Abuse Services, including Acting General Counsel, Deputy Counsel, and Associate Counsel.  He can be reached at (518) 462-5601 or via e-mail at

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