Are You Employing Someone on the Exclusion List?

How would you know?

If you are in the healthcare business, you must be regularly searching the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General’s Exclusion List (http://exclusions.oig.hhs.gov/).

On May 8, 2013, the OIG issued an Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (Special Advisory Bulletin).  These guidelines recommend that health care providers screen their employees and contractors monthly to confirm that they are not on the OIG’s List of Excluded Individuals/Entities.

Under the law, no Federal health care program payment may be made for any item or service furnished by an excluded person or at the medical direction or on the prescription of an excluded person.  In addition, the Affordable Care Act of 2010 extends CMP liability to providers that provide other items or services prescribed or ordered by an excluded person.

Health care providers that violate this provision risk imposition of civil monetary penalties (“CMPs”) of up to $10,000 for each item or service furnished by the excluded person, as well as an assessment of up to three times the amount claimed.  In serious cases, the provider itself could face exclusion. Article.

What should you do?

  • Check monthly on the exclusion list for all employees and contractors.
  • Screen all physicians and healthcare providers prior to billing for their services.
  • Keep a record of your monthly screenings.
  • Update your compliance program to include a policy regarding screening.

Your company does not want to inadvertently work with an excluded provider.  If you or your entity needs assistance with the intricacies of searching for excluded providers, please do not hesitate to contact our office – we can help.  For assistance CLICK HERE.

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