OMIG SADC Audit Protocol: What Providers Should Prepare Now

OMIG’s current audit-protocol page lists both Social Adult Day Care (SADC) and Adult Day Health Care (ADHC) under New Protocols in Development. For both, the targeted publication date is still marked Pending.

For New York providers, that does not mean a finished audit checklist already exists. OMIG says Pending for a new protocol reflects early-stage development while a target publication date is being established.

The practical response is not to guess what the final protocol will say. It is to make sure the records you already maintain under current Medicaid, Department of Health, MLTC, program, and contractual requirements are organized, consistent, and retrievable.

If a reviewer selects one member, one date, or one claim, can your team quickly connect the supporting attendance, plan, service documentation, billing record, and any later correction?

What Is the Current Status of the OMIG SADC Audit Protocol?

As of August 27, 2026, OMIG’s audit-protocol page lists Social Adult Day Care as a new audit protocol in development with its targeted publication date marked Pending.

The OMIG ADHC audit protocol is on the same development list and is also marked Pending.

OMIG explains that new audit protocols move through several stages before final publication.

• Initial drafting by subject-matter experts
• Program-agency review
• Internal quality and legal review
• Provider-association stakeholder review
• Final OMIG review and publication

That process matters because providers should not treat an unpublished protocol as if its final audit criteria are already known.

OMIG also states that audit protocols are guidance. They summarize audit criteria based on applicable rules and agency policy, but they do not replace or change the underlying statutes and regulations.

What Does Pending Mean for SADC and ADHC Providers?

For a new protocol, OMIG says Pending means the protocol is still in early-stage development while a target publication date is being established.

• There is not yet a published SADC OMIG protocol to follow line by line
• There is not yet a published ADHC OMIG protocol to follow line by line
• Providers should continue following the requirements already applicable to their program
• Providers should avoid claiming they know the final OMIG criteria before publication

This distinction matters especially for SADC operators because New York already has a separate Department of Health compliance-review process. All SADCs contracted with MLTC plans are reviewed annually for ongoing state and federal compliance.

That existing SADC compliance review New York providers already participate in is not the same process as the pending OMIG audit protocol.

What Can SADC Providers Prepare Before the OMIG Protocol Is Published?

No provider can responsibly build a final OMIG checklist until OMIG publishes the protocol. What you can do is test whether the records you already maintain can support the participant day, service, and billing trail without a last-minute reconstruction.

For broader recordkeeping considerations, see our adult day care documentation requirements guide.

These categories are not a prediction of the final OMIG protocol. They reflect common operational records and issues already visible in current New York SADC oversight.

1. Make Attendance Easy to Reconcile

A 2026 New York State Comptroller SADC audit reported that 7,964 of 92,969 encounter claims reviewed at three SADC facilities were not supported by the sign-in logs used by those facilities, representing $672,147 in payments.

That finding does not establish one universal attendance format. It does show why attendance evidence can become important when a reviewer asks whether a service occurred.

Your adult day care attendance records should be easy to retrieve and compare with the day’s service documentation and billing information. If paper sheets or editable spreadsheets make that difficult, review how adult day care attendance tracking can preserve time-stamped entries and correction history.

2. Review Assessments and Person-Centered Service Plans

The same Comptroller audit reviewed 15 member files at two SADC sites and reported non-compliance in 14, including claims before a required initial assessment and missing or unsigned Person-Centered Service Plans.

PCSPs are also a current operational issue for New York SADC providers. NYSDOH released an updated SADC PCSP template and user guide for use or alignment by May 1, 2026.

Do not wait for a future OMIG protocol to discover that a required plan is missing, unsigned, outdated, or difficult to match to the member’s service history.

3. Reconcile Billing and Encounter Data With the Day Behind It

A claim or encounter record is the end of the workflow. For an internal sample, work backward from what was submitted.

Can you locate the member, applicable authorization, plan, attendance evidence, and required daily documentation for the same date?

Our adult day care Medicaid billing software guide explains why keeping billing close to attendance and documentation can reduce manual reconciliation later.

This does not guarantee that a record will satisfy OMIG, NYSDOH, an MLTC plan, or another reviewer. It makes inconsistencies easier for your own team to identify.

4. Review Capacity, Facility Records, and Corrections

The Comptroller audit also identified Certificate of Occupancy and capacity concerns. At one location, auditors reported 386 service dates where encounter data indicated attendance above the site’s documented capacity.

Software cannot determine whether a Certificate of Occupancy or another facility document is legally sufficient. But centers should not treat operational headcount, facility documentation, and billing as unrelated.

Corrections also matter. If staff correct an attendance time or another important entry, follow the applicable correction rules and preserve enough history for the change to be understood later.

If a discrepancy could materially affect a claim or compliance obligation, involve the appropriate billing, compliance, or legal professional rather than reconstructing missing history.

How Can Current NYSDOH SADC Reviews Help You Prepare?

New York’s existing annual SADC compliance-review process gives providers a practical readiness test today.

According to NYSDOH’s SADC compliance review guidance, all SADCs contracted with MLTC plans must undergo annual review.

The Department generally contacts the MLTC plan about six weeks in advance. After scheduling, the Department provides compliance questions, requests a member roster, and directs the plan to use the SADC Compliance Review Preliminary Information Checklist.

NYSDOH says requested checklist materials should be submitted within 10 business days of the request.

That creates a useful readiness question: could your center accurately assemble current review materials without depending on one employee’s memory or spending days searching paper binders and separate spreadsheets?

For a broader internal exercise, use our adult day care audit checklist.

ADHC providers should not simply apply SADC-specific NYSDOH review requirements to their own programs. OMIG is developing a separate ADHC protocol, and Adult Day Health Care providers should continue following the rules and program requirements that currently apply to them.

How Far Back Can an OMIG Audit Look?

OMIG’s Audit Protocol Frequently Asked Questions says audits are generally limited to services furnished or billed, whichever is later, within the six years before OMIG’s notice of intent to audit.

OMIG also notes that a longer timeframe may be reviewed where fraud may be involved.

The service-date range eventually printed on an audit protocol is not the same thing as the scope of an individual audit. OMIG says the protocol’s date range provides regulatory and policy context.

For providers, the operational lesson is straightforward: audit readiness is not only about this month’s records. Retrieval and consistency across earlier years can matter too.

How Can Adult Day Genie Help With SADC Audit Preparation?

Adult Day Genie keeps the participant’s operational record connected across the day. Member information, authorizations, care plans and forms, attendance, daily documentation, reporting, and Medicaid billing can stay closer together instead of being split across paper logs, spreadsheets, and separate systems.

Attendance can be recorded through consent-based face confirmation or manual staff check-in. Entries are time-stamped, and corrections append to the history rather than quietly replacing an earlier event.

You can review the broader workflow on the Adult Day Genie features page.

Adult Day Genie does not know the unpublished OMIG criteria, cannot guarantee compliance, and cannot prevent an audit or disallowance. OMIG, NYSDOH, MLTC plans, payers, and other reviewers apply the requirements relevant to their work.

The operational value is simpler: when someone asks for the record behind a participant day, your team has fewer disconnected places to search.

What Should New York Adult Day Providers Do Now?

Do not build a checklist around a protocol that has not been published. Instead, focus on the requirements and records that already apply.

1. Confirm which current Medicaid, state, program, MLTC, payer, and contractual requirements apply
2. Review several recent participant records from authorization or plan through attendance, documentation, and billing
3. Check whether corrections remain traceable
4. Make sure current SADC compliance-review materials can be produced without a scramble
5. Identify recurring workflow gaps and fix the process creating them
6. Monitor OMIG’s official audit-protocol page for publication of the SADC or ADHC protocol

The strongest preparation is not predicting OMIG’s final wording. It is maintaining accurate records under the rules that already apply and being able to retrieve those records when asked.

If your center still reconstructs participant days from paper attendance, separate documentation, and disconnected billing records, see Adult Day Genie in a 15-minute walkthrough.

Frequently Asked Questions

This article provides operational information, not legal, billing, or compliance advice. Providers should confirm requirements with OMIG, NYSDOH, applicable Medicaid programs, MLTC plans, payers, contracts, and qualified professional advisers.