Jul 23 / Alex Lipovtsev & Dianne Pledgie

OMIG Updates Compliance Program Review Module: What New York Health Centers Should Know

The New York State Office of the Medicaid Inspector General (OMIG) recently released an updated Compliance Program Review Module, the tool providers must complete during an OMIG Compliance Program Review (CPR). OMIG announced it will use the updated CPR Module for submissions starting on July 6, 2026.

For health care providers enrolled in New York Medicaid, the publicly available CPR Module provides an opportunity to assess compliance using the same tool OMIG uses to determine whether providers have implemented a compliance program that meets the requirements under Social Services Law § 363-d and 18 NYCRR SubPart 521-1.

The chart below highlights some of the key changes between the prior version of the CPR Module (2023) and the current updated version, although it is not an exhaustive list of every change.
OMIG CPR Module: 2023 vs. Updated 2026
Topic 2023 CPR Module Updated 2026 CPR Module
Annual certification
18 NYCRR § 521-1.3(f)		 Not addressed in the Module. New section. Asks whether the provider filed the Certification Statement for Provider Billing Medicaid with the State Department of Health (SDOH) during the Review Period, and whether participating providers gave a copy of the certification to each Medicaid managed care organization for which they are a participating provider — with documentation requested for both.
Attestation None. The person completing the CPR Module must check a box attesting that responses and supporting documentation are true and accurate.
Documentation tracking Documents labeled by “Attachment” number (e.g., Attachment 1-1a) and itemized in a single master documentation table at the end of the CPR Module. Removed the attachment numbering system and master documentation table. Added documentation table after each question with fields to list effective dates and an “Additional Comments” box.
Review Period coverage Several questions required Providers to identify each month during the Review Period when the requirement was in effect by checking a box next to the month or selecting “none.” The check boxes have been eliminated; however, the same information is collected by submitting the documentation in effect during the Review Period and listing the effective date for each document.
Question structure Included several compound questions. For example,
  • Were written policies compliant and applicable to all Affected Individuals? (Question 1-1)
  • Did the provider maintain reporter confidentiality and post compliance program information on its website? (Question 4-3)
 Compound questions split into separate yes/no questions, each with its own documentation request.
Responding to compliance issues
Element 7		 Included three questions on compliance with 18 NYCRR § 521-1.4(h) during the Review Period:
  • 7-1: If potential compliance issues were detected, did the Provider comply with 18 NYCRR § 521-1.4(h)?
  • 7-2: If the provider had an OMIG audit or investigation, that was finalized and resulted in overpayments, did the Provider comply with the requirements of 18 NYCRR § 521-1.4(h)(1)?
  • 7-3: If the provider had a Self-Disclosure and Compliance Agreement that included plans of correction to resolve the reasons for the overpayments and prevent recurrence, did the Provider implement such plans of correction?
 Removed Questions 7-2 and 7-3. Remaining Question 7-1 asks whether the provider complied with § 521-1.4(h) when potential compliance issues were detected. This shifts the Module’s focus to the provider’s internal processes for addressing compliance issues, rather than tracking the status of OMIG audits, self-disclosures, or compliance agreements.
Provider ID acknowledgment Confirm all Provider IDs are enrolled under the same FEIN and covered by the same compliance program. Confirm all Provider IDs are covered by the same compliance program and the same compliance officer, plus a brief description of the services provided under each Provider ID.
Submission options Submit by email to OMIG’s Bureau of Compliance. Email remains preferred, with new options to split large productions across multiple emails, request a link to OMIG’s secure submission portal, or submit compressed ZIP files.

Source: OMIG Compliance Program Review Module (prior and updated versions). This chart summarizes key changes and is not an exhaustive list.

What New York Health Centers Need To Know:

  • Annual compliance program reviews are mandatory for every health center participating in NYS Medicaid.

  • Annual compliance program reviews must be conducted by someone knowledgeable about compliance programs and independent of compliance program functions. That likely rules out your compliance officer, and the task may fall to your compliance committee or an external reviewer.

  • If you use the CPR Module as a self-assessment tool, use the 2026 version. Keep in mind that the self-assessment creates a paper trail – if it flags a compliance gap and your health center doesn’t act on it, that document could later be used to show you knew, or should have known, about the noncompliance.

  • Already completed your 2026 annual review? Amend it to reflect the changes in the 2026 CPR Module.

Questions about evaluating your compliance program?

Our team of knowledgeable, independent reviewers can evaluate your health center’s compliance program and create a work plan designed to build a better program.
Questions about responding to an OMIG CPR?
Our team has experience helping health centers develop successful responses. From the initial Notification Letter to requests for additional information from OIG and developing corrective action plans, Powers Law is available to support your health center.

Contact us to learn more:

DIANNE PLEDGIE
Principal
dianne.pledgie@powerslaw.com
ALEX LIPOVTSEV
Manager, Compliance and Risk Management Services
alex.lipovtsev@powerslaw.com