Certifying Medicaid program data, Part 2: Pre-data submission diligence

Jay Davis (jaydavis@jaydavislegal.com) is an Attorney focusing in privacy, ethics, compliance, and healthcare, practicing in the greater Los Angeles area.

Part 1 of this article appeared in the December 2017 issue of Compliance Today.

Part 1 of this article presented an overview of the recently overhauled Medicaid managed care program regulations and the need to conduct pre-submission diligence to validate the accuracy, completeness, and truthfulness of the certified data submissions. To help meet the new requirements, a data validation and testing process should be integrated into existing managed care compliance programs.

Part 2 presents two examples of implementing a pre-submission data diligent review, testing, and validation process. The examples illustrate how a Compliance department-driven, pre-submission review process can promote Medicaid program compliance and integrity, lessen regulatory sanctions, and protect against potential claims under the False Claims Act.

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