NYSHFA Staff Discuss OMIG Audits with DOH

Nancy Leveille and Karen Morris in Clinical & Quality

Nancy Leveille and Karen Morris, NYSHFA, met with DOH staff on Monday January, 6, 2015 to discuss issues members have brought forth related to the current OMIG audits. We presented them with information on topics that we prioritized in consultation with our associate member, Sheryl Rosenfield, Zimmet Healthcare Services Group LLC and staff at LANYS and HANYS. The DOH actively listed to our concerns and confirmed that they want to develop a FAQ document to clarify questions similar to their approach with the PRI system. DOH noted they had an interest in discussing all items with OMIG staff and would clarify issues as soon as possible. We requested that if there is a specific direction they want providers to use for certain items, like we agreed to with specific PRI items, they will identify those and communicate them to all providers before implementing them into the audit process. In addition, we all agreed, those items cannot cause undo extra work for providers. Our collective goals were to have an auditing process that is transparent and objectively uses the directions set for by CMS for the completing the MDS via the RAI manual. The following is a summary of discussion points:

  • The need for effective education related to audit outcomes. We had previously requested to have prior input from associations to ensure the information would be relevant to the current issues.
  • PRI vs MDS issues: Discussed concerns how the PRI process appeared to be¬† being used instead of the MDS definitions
  • Medical record: addressed the need for the use of full medical record for auditing purposes and not being limited to specific items that OMIG identified in a letter to providers. In addition, we reviewed the legal parts of a medical record.
  • ADLS and their MDS documentation requirements
  • MD orders: Discussed the MDS definitions of what qualifies for this element of the MDS and also the definition of sliding slide vs the standard of practice for managing a patient on Coumadin therapy.
  • Active diagnosis¬† and what qualifies for a MD visit based on MDS definition
  • Rehab issues related to start of therapy and physical therapy for pain management
  • Behavior occurrence and the required MDS documentation


Nancy Leveille, RN, MS
Sr. Director, Member Operational Support
518-462-4800 x20

Karen Morris, RN, MS
Director, Clinical & Quality Services
518-462-4800 x15