Corporate Compliance Ethics Week

This article was written by Paul Mayer, June Crawford, and Heather Brownson.

To celebrate this year’s Corporate Compliance & Ethics Week (11/5-11/11 2023), The Compliance Solutions team at The Bonadio Group wanted to share a few important reminders related to New York State’s mandatory compliance program requirements.

On December 28, 2022, the Office of Medicaid Inspector General (OMIG) finalized and made effective the 18 NYCRR Part 521 Regulations. These regulations were updated to meet the amendments of the New York State Social Service Law Section 363-D.

Some of the significant changes include but are not limited to:

• Requiring a Compliance Committee and Committee Charter, and annual review of the Charter.
• Developing and maintaining an effective Compliance Training Program for the Compliance Officer and affected individuals, inclusive of an annual Training Plan.
• Requiring an annual Compliance Work Plan.
• Requiring an annual effectiveness review of the Compliance Program, Policies & Procedures and Standards of Conduct.
• Quarterly Reporting by the Compliance Officer to the Compliance Committee, Executive Director and Board.
• Requiring Exclusion Screening at least every 30 days.
• Self-Disclosure for any identified overpayment.

Compliance Solutions can:

1. Assist in the development of compliance plan documents and supporting policies and procedures, and
2. Conduct compliance program gap analyses so work plans can be effectively developed to correct any shortcomings in your program,
3. Conduct compliance program effectiveness reviews to confirm the operation of an effective compliance program, per Part 521 requirements,
4. Perform ongoing auditing and monitoring services.

Our Compliance Solutions team has years of hands-on experience. Made up of Compliance Officers, Registered Nurses, Quality Assurance and HIPAA personnel and members of Boards of Directors at a variety of organizations, our team works with clients to create programs aligned with the latest regulatory changes to produce better business and performance outcomes.

Paul Mayer, Executive Vice President, leads the firm’s Compliance Solutions Team. With more than 15 years of experience in not-for-profit settings and 17 years in compliance consulting, Paul is a great Compliance Program resource for his clients. He has held several positions for organizations regulated by local state and federal laws including Corporate Compliance Officer, Director of Corporate Compliance, and more. Additionally, Paul has conducted compliance trainings and assessed compliance programs for organizations throughout the country.

June Crawford, Director in the Compliance Solutions Division, is a Registered Professional Nurse and has more than 25 years of experience in a broad spectrum of health care providers. June transferred her knowledge and experience to assist clients with all aspects of compliance, HIPAA implementation and policy development.

Heather Brownson is a Senior Consultant in the Compliance Solutions Division. She has more than 15 years of experience in healthcare and not-for-profit settings. Heather utilizes her knowledge and experience to assist clients with all aspects of compliance, policy development and incident management.

The Bonadio Group does not provide legal advice and counsel, so we recommend you consult your attorney on legal matters.

If you need further guidance or have any questions on this topic, we’re here to help. Please do not hesitate to reach out to our trusted experts to discuss your specific situation.

This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.