(March 3, 2022): The last two years have been rough for everyone, and it has been particularly difficult for health care providers and suppliers. For example, the rapid spread of the Covid Omicron variant not only threatened to overwhelm a health care system that was already stretched to its limits, it also made it tougher… more>>
(November 2, 2021): The Centers for Medicare and Medicaid Services (CMS)[1] is the Federal agency tasked with the overall responsibility of managing the Medicare program. Thus, while the Office of Inspector General (OIG) is the primary agency responsible for protecting the integrity of the Medicare program, CMS and its various contractors serve as the program’s… more>>
When an Underlying Misdemeanor or Felony Conviction is Expunged, Does That Extinguish an Exclusion Action?(October 25, 2021): Medicare and Medicaid providers / suppliers are prohibited from employing individuals who have been excluded from participation in Federal health care benefits programs. Similarly, participating providers and suppliers are also obligated to ensure that any business affiliates (such… more>>
To understand the North Carolina Exclusion Screening Requirements, we must first touch upon Exclusions in general. Office of Inspector General (OIG) exclusions are one of the most powerful weapons available to the law enforcement in its efforts to fight healthcare fraud. Individuals and entities subject to an OIG exclusion are barred from participation in all… more>>
Since the CMS Preclusion list was announced in April 2018, and then published in January 2019, there has been confusion and questions regarding the list, its differences from the OIG Exclusion List, the size of the list, and who has access. Unfortunately, the publication of the list has added further complexity to the already complicated… more>>
What is the Length of a Mandatory Exclusion?(January 8th, 2021): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) is responsible for overseeing the financial and program integrity of more than 100 HHS programs, one of which is the Medicare program. As you would imagine, the Medicare program is quite costly. … more>>
(December 22nd, 2020): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) exercises both mandatory and permissive exclusion authority with respect to Federal health care programs.[1] In a recent New York case, the OIG was required by law to mandatorily exclude an individual for a minimum of five years due to… more>>
Why is it Necessary to Screen Against the NPPES Registry? (December 7th, 2020): We are sometimes asked “Why do you screen against the National Plan and Provider Enumeration System (NPPES).” That is a great question. Many health care providers are only familiar with the exclusion database maintained by the Department of Health and Human Services (HHS),… more>>
Exclusion Actions Under 42 U.S.C. § 1320a-7(b)(5)(B) (November 2020): Since 1976, the Department of Health and Human Services (HHS), Office of Inspector General (OIG) has been at the forefront of our nation’s efforts to fight waste, fraud and abuse in the Medicare, Medicaid and more than 100 other programs. Collectively, the costs of the federal programs… more>>
A State Conviction for “Patient Neglect” Will Result in Mandatory Exclusion from Participation in Federal Health Benefit Programs (March 27, 2020): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) may be required by law under Section 1128 of the Social Security Act to exclude individuals and entities from participating in Federal… more>>