Compliance Plan Reference Material

January 2010 Presentation on Compliance Plans

• OIG Presentation On Excluded Provider Requirement from 2009

• OIG Exclusion Policy

• CMS Directive - All Medicaid providers must do monthly check of employees and contractors.

"States should require providers to search the HHS-OIG website monthly to capture
exclusions and reinstatements that have occurred since the last search."

• CMS Directive to States to Check for Excluded Providers Every Month

"State data files should capture these important data elements so that an automated comparison of exclusions against a provider file that includes the names of individuals with ownership or control interests in provider entities  can be accomplished easily during regular monthly searches and at any time providers submit new disclosure information to the State."

• NYS List of School over$400,000 - caution this can only include a school in the need for a compliance plan. If your district is not listed you are not necessarily excluded from the requirement.

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• NYS OMIG Clarifies the Director of Special Education may be the Compliance Officer and the NYS Education Department recommends that all schools have Compliance Plans. posted 12/20/2010

• Chenango Forks

• Bay Shore School District Plan

• Watervliet Board Policy

• Watervliet Plan

• Onondaga County Plan

• Onondaga Updated Policy/Plan 12/30/2009

• Monroe Woodbury

• NYSSBA'S Legal Alert

• Template Board Policy

• Main Components of Compliance Plan

• Excellent Outline of plan requirements from The Coalition for Behavioral Health Agencies of New York, Inc.

• Link to KINNEY compliance plan

• Link to NYS OMIG Mandatory Compliance Plan Certification