DSRIP Compliance Requirements – Updated February 8, 2018
Under New York State law and requirements of the Office of Medicaid Inspector General (OMIG), all OneCity Health partners need to provide their workforce with New York State Delivery System Reform Incentive Payment (DSRIP) compliance training in the first half of 2018.
This is also a Phase III Participation Requirement in our partners Phase III Comprehensive Schedule B. Please see Section E in the sample Phase III Comprehensive Schedule B we posted to our website in December, 2017
We have prepared materials to help our partners easily meet this requirement by June 30, 2018.
Below please find:
- Background on DSRIP compliance training
- How to meet this requirement
- Next steps
- Who to contact with questions
- How to attest to completion of compliance training
We appreciate our partners’ support in meeting this New York State obligation
About DSRIP Compliance Training
In the “Downloads” box to the right, please find a memorandum prepared by the NYC Health + Hospitals/OneCity Health Office of Corporate Compliance (OCC) which details the requirement that partners provide their workforce members who are involved or associated with, or otherwise affected by, the DSRIP Program, with DSRIP compliance training.
How to Meet this Requirement
To assist partners, within the memorandum (beginning page 9) is a presentation titled “Delivery System Reform Incentive Payment Program Compliance Training and Education.” The PowerPoint addresses the following:
- Introduction to DSRIP
- General Compliance Requirements for Medicaid Providers
- Special Considerations for DSRIP Compliance
- Fraud, Waste and Abuse & Relevant Laws
- Reporting Compliance Issues
OneCity Health partners are welcome to utilize this presentation to satisfy their DSRIP compliance training and education requirements. Specifically, they can:
- Use it to develop a presentation for in-person/live compliance and education training;
- Incorporate the content of the PowerPoint into their existing compliance training and education computerized modules (e.g., automated online training); or
- Simply distribute the PowerPoint to their workforce members involved with or otherwise affected by the DSRIP program.
We recommend our partners consult with their legal counsel if they have questions.
About the Attestation
We have developed the Attestation to assess the compliance program integrity of OneCity Health Partners. The attestation asks you to disclose the following compliance-related information:
- The status of completion of DSRIP compliance training by their medical practice or organization;
- An acknowledgment by partners that their workforce members are familiar with and adhere to the NYC Health + Hospitals Principles of Professional Conduct or their own code of conduct that includes the core objectives or substantially similar compliance goals as the Principles of Professional Conduct; and
- Proof of OMIG compliance program-related certifications including the Deficit Reduction Act of 2005 certification by those partners that are required by law and/or OMIG policy to submit such certifications.
For further information, please refer to the “DSRIP Compliance Attestation of OneCity Health Partners” memo in the “Downloads” box to the right
How to Attest
This year, to make attestation easier, you simply need to complete an online survey here
For REFERENCE ONLY, the survey is available in the “Downloads” box to the right
As a reminder, the deadline to complete the training and submit the attestation via the online survey is June 30, 2018.
Catherine G. Patsos, Esq.
Acting Chief Corporate Compliance Officer Corporate Privacy and Security Officer Office of Corporate Compliance NYC Health + Hospitals
Sofia R. Khalid, Esq.
Assistant Compliance Officer
Phone: (646) 458-6443
Deficit Reduction Act of 2005 – Posted September 29, 2017
Under the Deficit Reduction Act of 2005, NYC Health + Hospitals is required to inform all NYC Health + Hospitals/OneCity Health (“OneCity Health”) Workforce Members and Business Partners about its internal policies covering fraud, waste and abuse; the Federal False Claims Act and any similar law under the State of New York that governs false claims and statements; and whistleblower protections under Federal and State laws.
In accordance with this requirement, this memorandum from Wayne A. McNulty, Senior Assistant Vice President & Chief Corporate Compliance Officer, Office of Corporate Compliance (“OCC”), provides an overview of these policies and laws, respectively.