by Cheryl Nash
When we think of the term Compliance a lot of acronyms come to mind for the Medical Practice. OSHA, HIPAA, OCR, RAC, the list goes on and on, but one acronym, OIG, while familiar has a regulation a lot of new practices and even some more established ones are unaware of. This is the regulation requiring you to check the exclusion list.
The OIG LEIE (list of excluded individuals and entities) is a database of entities that have been excluded from participation in a Federal healthcare program. This includes Medicare, Medicaid, Tricare and VA. Individuals and entities are excluded for a number of reasons, such as being convicted of healthcare fraud and abuse.
“Any items and services furnished by an excluded individual or entity are not reimbursable under Federal health care programs. In addition, any items and services furnished at the medical direction or prescription of an excluded physician are not reimbursable when the individual or entity furnishing the services either knows or should know of the exclusion.”
A healthcare practice is banned from employing or contracting anyone that is active on the exclusion list. All employees, vendors, or subcontractors should be screened prior to retaining in a professional capacity. After hiring or contracting, they should be checked regularly to ensure no changes in their status.
There are penalties for engaging in business with an individual or entity on this list. A 10k fine per instance plus up to triple damages may be sought if found in violation. The OIG doesn’t play around!
The LEIE has a quick searchable online link found here Exclusions.oig
Exclusion lists exist across many agencies and at both state and federal levels, and any that pertain to your practice should be checked to ensure practice compliance. A helpful link to other agencies can be found at AtlasCertified.com.
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