What is an OIG Exclusion?
OIG has the authority to exclude individuals and entities from Federally funded health care programs for a variety of reasons, including a conviction for Medicare or Medicaid fraud. Those that are excluded can receive no payment from Federal healthcare programs for any items or services they furnish, order, or prescribe. This includes those that provide health benefits funded directly or indirectly by the United States (other than the Federal Employees Health Benefits Plan).
What is OIG Exclusion screening?
The OIG, or Office of the Inspector General, exclusion screening is the verification process to check the status of employees and/or potential employees for exclusions from participating in any/all Federal health care programs.
How often should employees be rescreened for OIG exclusions?
Employees should be screened for exclusions every month and through all state and federal registries.
When were OIG exclusions first implemented?
OIG has been implementing exclusions since about 1981, but the Department of Health & Human Services first began imposing them in 1977.
What is an example of exclusionary criteria?
OIG exclusion criteria can range in offense but is generally thought of as crimes or wrongdoings related to fraud, abuse, neglect, theft, or related misconduct by health and human services workers. According to the OIG government site,
”OIG is required by law to exclude from participation in all Federal health care programs individuals and entities convicted of the following types of criminal offenses: Medicare or Medicaid fraud, as well as any other offenses related to the delivery of items or services under Medicare, Medicaid, SCHIP, or other State health care programs; patient abuse or neglect; felony convictions for other health care-related fraud, theft, or other financial misconduct; and felony convictions relating to unlawful manufacture, distribution, prescription, or dispensing of controlled substances.”
As an employer, how do I find out if an entity or individual is excluded?
Searching the Federal exclusions database for potential exclusions should be done monthly. Employment Screening Services provides these monthly checks for employers and companies. It should be noted that each state has different laws and requirements regarding exclusions and addition searches may be required to ensure the validity of each employment verification.
What should I do if I receive a positive confirmation from exclusion screening?
It is recommended to end the relationship with said person or entity and make your company’s legal counsel aware of the situation.
Our staff has not changed in years, no one of our employees are excluded, is it necessary to continue to do OIG exclusion screenings on a monthly basis?
Though this is a common query, Yes, exclusion screening current and longstanding employees is still necessary. The state of your company’s records keeping in these matters is important; if your records are not up to date and your company hires or continues to employ a person or entity on the LEIE, there are penalties.
What is LEIE, and what can be done for my business with this information?
The LEIE or List of Excluded Individuals/Entities is a monthly updated list of persons and entities that have been excluded from receiving payments or monies from Medicare, Medicaid, and all federal healthcare provides information for the healthcare industry, patients, and other healthcare programs. It is imperative for employers to know whether their employees or potential hires are not on the LEIE. Persons or entities on the list are liable to incur monetary penalties for subverting employers in gaining or continuing employment/payments, and businesses are as well liable to be penalized if they have hired or make payments to persons or entities on the LEIE.
How is OIG exclusion screening verification done?
An OIG exclusion screening verification is done by entering the current or potential employees name and other personal information into the OIG database. The database will then return with a list of potential matches to the information entered based on similar names, spellings, and/or alterations of names. Then the employer must corroborate the potential or current employee’s information with the information from the OIG database to verify a match or deem the employee clear of any exclusions. It is important for employers to check candidates and employees name alterations, including but not limited to, maiden names, names that have been changed or altered, and other diminutives.
As an Employer, is it required to search every state's databases to complete a OIG exclusion search?
Yes. Though the OIG database that is made available to employers searching for exclusions does generally cover much of what an individual or entity would be excluded for, it is still required to verify each employment candidate and current employee with all the databases nationwide to remain in compliance with local, state, and federal law.
Employment Screening Services, LLC
PO Box 1108
Williamsville, NY 14231
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