Of the many responsibilities healthcare providers hold, one with serious financial implications is compliance with the Office of the Inspector General. The OIG can exclude individuals or parties from being employed or contracted by any provider who receives payment from federal health programs such as Medicare and Medicaid. Here’s what you need to know about how that affects your organization:
- Your Organization Is at Risk If You Hire Excluded Individuals
If it’s discovered that you’ve hired someone who has been excluded by the OIG, then your organization is subject to financial penalties. This is why regular OIG exclusion screening is actually in your best interest. It’s important to note that individuals on the List of Excluded Individuals and Entities (LEIE) cannot be hired in any capacity, even ones that do not deal directly with patient care.
- Potential Matches Require Further Investigation
It’s important to note that a match on the exclusion database doesn’t necessary indicate that you’ve hired an excluded individual; this is because matches are based not on completely unique characteristics such as social security numbers, but on names. So when you get a potential match, you need to either start an internal investigation or outsource that employee verification process to a company that specializes in such matters.
- Self-Disclosure Can Help You Avoid Monetary Penalties
If you do find after a search on the exclusion database that you’ve employed someone on the LEIE, then the best thing you can do is self-report to the Office of the Inspector General. This can allow you to avoid civil monetary penalties associated with hiring an excluded individual, as well as the disruption a government investigation can cause.
- The List Applies to Payment, not Care, of Excluded Individuals
Exclusion screening should be applied only to employees or contractors. Excluded individuals aren’t prohibited from receiving treatment under Medicare or Medicaid; they’re only prohibited from being paid for services.
- Individuals Are Removed From the List Upon Reinstatement
It is possible for individuals to be reinstated by the OIG. However, when they go through this process, their names will be removed from the LEIE, which is regularly updated. So you shouldn’t hire anyone who claims to have been reinstated if the database doesn’t confirm their assertion.
Do you have any other helpful information to share about OIG compliance or the exclusion database? Add your thoughts in the comments.