Medicaid Compliance: Challenges for the Southern Tier AIDS Program as a Small Non-profit Organization

1
Medicaid Compliance Challenges for the Southern
Tier AIDS Program as a Small Non-profit
Organization
Theodore J. Leibowitz, MPA Candidate
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Overview of Presentation

• Introduction to Southern Tier AIDS Program
• Organization Problem and Research Question
• Brief Overview of Literature
• Methodology
• Three Findings
• Three Recommendations
• Conclusion

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The Southern Tier AIDS Program (STAP)

• Small 501c (3)
• Mission
• Providing Comprehensive HIV/AIDS Services in the
  Southern Tier of New York
• Education and outreach
• Testing
• Support to those living with HIV/AIDS

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Organizational Problem

• What are Medicaids Corporate Compliance
  Mandates?
• What did 2010 look like for STAPs Medicaid
  funded department?
• STAP Medicaid expenses 466,059
• STAP Medicaid revenue 465,828
• Net loss of 231
• STAP implementing their program effectively on a
  small scale and with limited resources
• priceless

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Research Question

• How can STAP meet the corporate compliance
  requirements of the OMIG within their
  organization while maximizing funds for direct
  client services utilizing the resources and staff
  that they have available?

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Existing Literature

• Public Administration Policy Implementation
• Top-down Approach (deLeon deLeon, 2002 Mischen
  Sinclair, 2007)
• Bottom-up Approach (deLeon deLeon, 2002
  Mischen Sinclair, 2007)
• Medicaid Corporate Compliance Implementation
• Contingency Model (Milenkovic, 2008 OToole,
  2000)
• Emphasis on Importance of Buy-in (Provan,
  1985 Milenkovic, 2008 Ryan, 1997)

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Methodology

• Participants
• Eight non-profit compliance offers
• Procedure
• Confidential Phone interviews
• 25 minutes in length

• Strengths
• Follow-up Questions
• Similar Size and Environment
• Limitations
• Participant Dishonesty
• Time Limitations

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Methodology contd

• Data Analysis
• Thematically Coded
• Organized by Based on Annual Budget

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Findings

• Finding One
• Reporting and investigation procedures varies
  based on size of organization
• Finding Two
• Medicaid Exclusion Database Screening varies
  based on size of organization
• Finding Three
• Internal Auditing Procedure varies based on size
  of organization

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Finding Two

• Medicaid Exclusion Database Screening
• Three Methods
• EPStaffCheck
• Contracted out
• Performed Manually

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Findings

• Finding One
• Reporting Procedures
• Finding Two
• Medicaid Exclusion Database Screening
• Finding Three
• Internal Auditing Procedure

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Recommendations

• One
• Develop a comprehensive reporting and
  investigation procedure
• Two
• Invest in healthcare management software for
  Medicaid exclusion database screening
• Three
• Develop an internal auditing procedure adapted
  from Medicaids online Tool

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Conclusion

• Meeting Medicaid mandates with limited resources
  is challenging for small non-profits but it can
  be done.
• Compliance implementation plans are most
  effective based on a contingency model.
• Small non-profits need to custom fit compliance
  techniques to their organization.