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I. OIG Report In the Office of the Inspector General’s (OIG) semiannual report to Congress, it claimed credit for excluding 2,297 individuals and entities from Medicare, Medicaid, and other Federal health care programs. The OIG also claimed credit for initiating 506 criminal and 267 civil actions. According to the OIG report, most of the exclusions resulted from convictions for crimes […]
Providers are often surprised to learn that a person can be excluded from participation in federal health care programs because of student loan default. In fact, the failure to repay student loans is one of the most common reasons people find themselves on an exclusion list.1 I. Federal Regulations Surrounding Student Loan Default & Exclusions The […]
I. Civil Monetary Penalties Twenty-five out of the fifty-five exclusion enforcement actions reported in 2014 have occurred in home health, hospice, or nursing and rehabilitation facilities. The Civil Monetary Penalties (CMPs) imposed in these cases range from $10,000 to $428,935 for employing just one individual that the employer knew or should have known was excluded […]
I. 2015 OIG Work Plan The Office of Inspector General’s (OIG) ongoing concern regarding exclusion enforcement is reflected in its 2015 OIG Work Plan. In the work plan, the OIG announced that its Office of Audit Services will study whether the operating divisions within its own agency have been taking adequate precautions to ensure that excluded or […]
I. Mandatory OIG Exclusions When the Office of Inspector General (OIG) considers imposing a mandatory exclusion, it sends the individual or entity a Notice of Intent to Exclude.[1] The Notice includes the reason for the proposed exclusion and the possible effect of an exclusion. It also gives the individual or […]
I. Excluded Providers The Office of the Inspector General (OIG) recently released a study on a subset of Florida’s Medicaid payments for pharmaceutical items. The study showed that in 2009 and 2010 the State agency made $180,000 in payments for pharmaceutical items prescribed by excluded providers. OIG, comparing this […]
I. Take It from CMS: If You’re Excluded in One State, You’re Excluded in All States Section 6401(b)(2) of the Affordable Care Act (ACA) required the Centers for Medicare and Medicaid Services (CMS) to create a national database where State agencies could share and access information about individuals and entities that were terminated from the […]
I. Which Exclusion Databases Do I Need to Screen? The Office of Inspector General (OIG) recommends that you screen your employees, contractors, and vendors every month against the List of Excluded Individuals and Entities (LEIE) and the System for Award Management (SAM). Your State Medicaid director mandates monthly screening of your State exclusion database, in […]
In May 2014, the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services published two proposed rules to implement provisions of the Affordable Care Act (ACA). The new rules add and expand upon OIG’s current exclusion and Civil Monetary Penalty (CMP) authority. I. Revisions to OIG’s Exclusion Authority The new […]