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Checking the OIG Excluded Individuals and Entities List – A Compliance Monitoring Mandate

July 11, 2013 0 Comments

The Office of Inspector General (OIG) released a new video to its array of social media educational offerings today on How to Use OIG’s Online Exclusions Database.  This new YouTube video supplements previous OIG training videos on exclusions and the use of the exclusions database.  If you are not using the Exclusions database, it is time to get started, and document at a minimum during the new employee hiring process as well as on an annual basis.  Larger practices should query the database on a more frequent basis, and if you participate in Medicaid your state may require that you verify exclusions on a monthly basis either through the OIG Exclusions database or a State database.  This is an monitoring activity that should be on all provider compliance calenders.

Under the Exclusion Statute [42 U.S.C. § 1320a-7] the OIG is required to exclude those who have been guilty of Medicare or Medicaid fraud, patient abuse or neglect or certain felony convictions.  Exclusion lists exist to prevent individuals and vendors from participating in providing services (as an employee, provider, or vendor)  or billing Medicare or Medicaid for services provided for both mandatory and permissive reasons.

Mandatory Exclusions:

  • Medicare or Medicaid fraud
  • Patient abuse or neglect
  • Felony convictions relating to unlawful production or dispensing of controlled substances

Permissive Exclusions:

  • Misdemeanor fraud of publicly funded programs
  • Misdemeanor convictions relating to unlawful production, or dispensing of controlled substances
  • Suspension, revocation, or surrender of a healthcare license for reasons or unprofessional conduct
  • Submission of false or fraudulent claims
  • Engaging in kickback arrangements
  • Defaulting on a health education loan

 

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Nancy Beckley

Nancy J. Beckley MS, MBA, CHC: President-Nancy Beckley & Associates LLC. Compliance outsourcing, risk assessment, compliance plans, compliance training, auditing, due diligence, investigation support for therapy providers.

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