HHS/OIG Exclusion List Violations

An important subject that should not be far from your mind is the OIG exclusions list. The HHS/OIG is not backing down on Employment of Excluded Individuals. On April 1 and again on April 6, one organization had two reportable Corporate Integrity Act (CIA) Events. After the company disclosed conduct to OIG pursuant to its CIA, the company and facilities it manages entered into settlement agreements of $121,783.31 and $38,384.96. OIG alleged they employed individuals “that it knew or should have known were excluded from participation in the California Medicaid program (Medi-Cal) and that no Medi-Cal payments could be made for items or services the individual furnished.”

April 1 reportable event

April 6 reportable event

Healthcare organizations are responsible for verifying not only their potential employees' ability to hold employment but also vetting any vendors. the List of Excluded Individuals/Entities (LEIE) Database can be searched via this link: https://exclusions.oig.hhs.gov/

Don't make a costly mistake, know the rules!

Sean M. Weiss, CHC, CMCO, CEMA, CPMA, CPC-P, CMPE, CPC, is a Partner/VP and Chief Compliance Officer for DoctorsManagement, LLC.