Healthcare providers, no matter their size, must consider numerous legal and ethical factors when hiring employees and performing services. One of the most important of these is compliance with the Office of the Inspector General’s exclusion guidelines. Here are answers to five of the most common questions regarding exclusion and its effect on healthcare providers:
What Is the OIG Exclusion List?
The OIG exclusion list, called the List of Excluded Individuals/Entities, is a list of people who are prohibited from claiming payment from any federal health programs, including both Medicare and Medicaid. This list is available to healthcare providers, patients and the public. Individuals are typically placed on the list because they have been convicted of Medicare or Medicaid fraud, patient neglect or abuse, or felonies related to patient care and/or the distribution of prescription drugs.
Does Exclusion Prevent an Individual From Being Treated?
It is important to note that being placed on the LEIE precludes a person from being paid through federal health programs for providing services; it does not mean that they are not allowed to be treated through Medicare or Medicaid.
Why Does OIG Healthcare Compliance Matter?
OIG healthcare compliance affects not only individuals, but healthcare providers. This is because, should any provider hire or contract services out to a person on the exclusion list, the federal government can refuse payment and subject the organization in question to monetary penalties. OIG compliance is one of the many reasons over two-thirds (68%) of healthcare providers have internal committees that oversee compliance and ethics. Of these, 41% are led by a chief compliance offer who reports findings and makes recommendations to the committee.
How Can I Screen for Excluded Individuals?
OIG exclusion screening can be conducted using a database provided by the OIG, made easier by supplementary software. However, one of the challenges of screening is that potential matches need to be confirmed (since matches are made based on names, and not social security numbers); some organizations handle investigations internally, while others prefer to contract those services out. OIG exclusion checks should be performed on a regular basis, since new employees are constantly being hired and the list is also being updated.
Is It Possible to Be Removed From the Exclusion List?
After the period of exclusion specified by the OIG, an individual can apply for reinstatement by contacting the Office of the Inspector General and filling out special forms. It’s important to note that reinstatement is not automatic after the exclusion period ends. If reinstatement is approved, the individual is removed from the exclusion list and can be safely hired by healthcare providers.
Do you have any other questions about OIG healthcare compliance? Join the discussion in the comments.