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I. Medicaid Exclusion Exclusion Screening, LLC conducts monthly checks of our clients’ employees, contractors, and vendors against the OIG-LEIE, GSA-SAM, and all available state lists. Most providers understand that they have an obligation to check their employees, contractors, and vendors against the OIG-LEIE prior to hiring and monthly thereafter. Fewer providers are aware of their […]
We have previously discussed that once a provider is excluded he may not furnish items or services paid for by the the Federal health care programs until he is eligible to apply for reinstatement and the Office of the Inspector General (OIG) approves this reinstatement request. The one exception to this general rule is that OIG […]
I. Federal and State Agencies Conducting Audits As many health care providers and suppliers have painfully learned over the last year, federal and state law enforcement agencies, along with many of the contractors with whom they work, are actively conducting audits of Medicare and Medicaid claims submitted to the government for coverage and payment. One […]
There are two federal databases that list persons and entities that have been excluded from participating in federal health care programs or receiving federal contracts. Checking and verifying individuals on the List of Excluded Individuals and Entities (LEIE) and the System for Award Management (SAM) should be part of any compliance exclusion screening program. The LEIE is […]
At Exclusion Screening, LLCSM, we know the ins-and-outs of the exclusion screening process. In our opinion, an effective screening process requires some mandatory tools. To ensure that there are no holes in your screening process make sure you have: 1 – A List of Employees and Vendors All providers need a complete list of employees […]
I. The Reinstatement Process Most exclusions are imposed for a definite time period. The question for an excluded individual or entity is: What happens at the end of the exclusion period? The answer is that the excluded individual or entity must apply for reinstatement. The U.S. Department […]
[visualizer id=”1978″] A quick review of the Office of Inspector General’s (OIG) exclusion enforcement actions might make one wonder why the Civil Monetary Penalties (CMPs) for some entities are only $10,000 while others are closer to $2,000,000. We were curious as well, and took a look into the factors that might contribute to the vast differences […]
HHS/OIG Deputy Inspector General Gary Cantrell testified earlier this year that States are failing to report all of the adverse actions taken by their Licensing Boards. He suggested that the “manner and time of the [reported] notices” are unreliable. Cantrell attributed these concerns to the “voluntary” nature of State reporting obligations.[1] I. The Impact on Exclusion […]
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 […]
By Paul Weidenfeld I. Concerns of the 2015 OIG Work Plan The Office of Inspector General (OIG) expressed concern regarding exclusion and suspension enforcement in its 2015 OIG 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 […]