OMIG Audits of MLTC Capitation Payments: Strategies for Defending and Preventing Recoupment


Thursday, July 25, 2024

10:00 – 11:00 AM

Join us next week for this complimentary, members-only webinar to examine strategies for addressing and defending Office of the Medicaid Inspector General (“OMIG”) audits of capitated payments received by managed long term care plans (“MLTCs”). 


Overpayments resulting from these audits can be substantial, as they typically involve capitated payments for several hundred members over a multi-year audit period. Recoupment is often based on allegations of no community-based services being provided during the month in question, lack of authorizations, lack of member qualification, members being out of the service area, deceased or incarcerated, and other grounds. Given the potential for significant recoupment, a comprehensive and robust defense to these OMIG audits once they are initiated, as well as the implementation of preventative compliance measures, are critical. 


Jennie L. Shufelt, partner at Harter Secrest & Emery LLP, will examine ways to defend against capitated payment audits initiated by OMIG, including both legal and evidentiary considerations, as well as recommended policies and practices that MLTCs can implement to ensure that appropriate and adequate documentation is maintained to support a plan’s entitlement to payment.

REGISTER HERE!

 As a regulatory compliance and corporate attorney, Jennie Shufelt, Esq. advises health care and non-health care clients on a wide range of regulatory, corporate and transactional matters. Jennie utilizes her broad healthcare and legal industry experience to help clients maximize opportunities while minimizing and resolving risks.


Jennie represents health care plans and providers on operational, compliance, transactional and governance matters. Her experience includes guiding clients through audits by the Office of the Medicaid Inspector General (OMIG) and investigations by the New York State Attorney General’s Medicaid Fraud Control Unit. She has worked with numerous clients to develop and evaluate compliance programs, and assists clients with compliance program reviews conducted by the OMIG’s Bureau of Compliance. She advises a range of health care providers including assisted living facilities, certified home health agencies, licensed home care services agencies, nursing homes, physician practices, transportation providers and managed care plans. 


Jennie’s corporate practice includes advising for profit and not-for-profit clients in a variety of industries on transactional and corporate matters including formation, contracting, mergers, acquisitions and sales, commercial real estate transactions and leases, and corporate governance.