(New York, NY) August 12, 2009 – The Office of the Medicaid Inspector General (“OMIG”) has issued its compliance plan and Early Intervention (“EI”) Providers are included. Traditionally, the OMIG has focused on healthcare related entities, but since EI is administered through the Department of Health, and funds are used to cover related services (physical, occupational, speech therapy, etc.) the OMIG is getting involved.

Pursuant to the new compliance program, EI providers are required to establish a formal corporate compliance program by September 29, 2009.  While Medicaid funded agencies generating in excess of $500,000 have previously been required to implement a corporate compliance program, this requirement has been expanded to EI providers.  Since EI providers are principally educational, providing special education and related services to children under 3 years of age, it is unclear as to how extensive such a plan needs to be for an EI Provider.  A traditional corporate compliance program considers such things as billing and related payments; medical necessity and quality of care; governance; mandatory reporting; staff licensing; and other identified risks.  The components of a corporate compliance program include formal documented policies and procedures; staff and board education and training; the designation of a compliance officer; and other policies on transparency, response to non-compliance, and identification of risk areas.

“Providers are scrambling to try to determine the extent and level of documentation that is needed in order to come into compliance with these new requirements,” said Kenneth Cerini, Partner at Cerini & Associates, a Bohemia based accounting firm with a concentration in special education providers.  “If EI providers have to comply with the same rules healthcare providers do, you may see a lot of providers stop providing much needed EI services.”

The healthcare compliance regulations are available at www.omig.state.ny.us.  For questions, or further information, please call Ken Cerini at 631-582-1600 x203 or e-mail him at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

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