The New York State Office of the Medicaid Inspector General (OMIG) Self-Disclosure Program has unveiled a new short-form option for most routine and transactional human errors in billing and claims. 

Healthcare providers are required to report, explain, and return all overpayments they receive from patient health insurance. The self-disclosure sections of these returns ask providers to "explain" the cause of overpayments. Providers walk a tightrope, balancing their need to comply, with the responsibility for any human errors on the part of their office. If a pattern of errors emerges, providers may ask an attorney to handle the disclosure and any corrective action plan that may be required. A showing of how the practice has changed their billing and bookkeeping procedures is included to assure the errors will not continue to occur. 

In an effort to minimize hesitation on the part of providers, and encourage greater compliance, NYS OMIG is now offering a short-form self disclosure option that all but eliminates the need for providers to craft explanatory language to describe the errors and their causes. 

The new short-form is an electronic submission with fields to identify the provider and their contact information, and an attached form on which to list the billing details of the claims being returned in the form of a spreadsheet. The form can even be sent as a monthly reconciliation summary, and can include voids and adjustments on any of the following: 

• Routine credit balance/coordination of benefits overpayments;
• Typographical human errors;
• Routine Net Available Monthly Income (NAMI) adjustments;
• Instance of missing or faulty authorization for services due to human error;
• Instance of missing or insufficient support documentation due to human error;
• Use of inappropriate rate, procedure, or fee code due to typographical or human error; 
• Routine recipient enrollment issue.

Providers are required to report, return, and explain these and any other overpayments within sixty (60) days of identification, or by the date any corresponding cost report was due, whichever is later. Social Services Law (SOS) §363-d(6).

The new Abbreviated Self-Disclosure Process will be offered in addition to the existing option of the full disclosure process for providers may who wish to use it, and for situations that are not routine and transactional.

OMIG expects to begin receiving disclosures under the Abbreviated Self-Disclosure Process in October, 2023.