We have previously discussed that once a provider is excluded he may not furnish items or services paid for by the the Federal health care programs until he is eligible to apply for reinstatement and the Office of the Inspector General (OIG) approves this reinstatement request. The one exception to this general rule is that OIG… more>>
I. Federal and State Agencies Conducting Audits As many health care providers and suppliers have painfully learned over the last year, federal and state law enforcement agencies, along with many of the contractors with whom they work, are actively conducting audits of Medicare and Medicaid claims submitted to the government for coverage and payment. One… more>>
Must Haves for a Proper Exclusion Screening ProcessAt Exclusion Screening, LLCSM, we know the ins-and-outs of the exclusion screening process. In our opinion, an effective screening process requires some mandatory tools. To ensure that there are no holes in your screening process make sure you have: 1 – A List of Employees and Vendors All… more>>
I. The OIG Exclusion Reinstatement Process Most exclusions are imposed for a definite time period. The question for an excluded individual or entity is: What happens at the end of the exclusion period? The answer is that the excluded individual or entity must apply for reinstatement. The U.S. Department of Health and Human Services (HHS)… more>>
I. OIG Recommends Monthly Screening While there is not a formal regulation that mandates monthly exclusion screening, OIG issued guidance in May 2013, which recommended that providers check their employees and contractors against the OIG-LEIE each month because the LEIE is updated on a monthly basis. Just how many new names could possibly be… more>>
A quick review of the Office of Inspector General's (OIG) exclusion enforcement actions might make one wonder why the Civil Monetary Penalties (CMPs) for some entities are only $10,000 while others are closer to $2,000,000. We were curious as well, and took a look into the factors that might contribute to the vast differences in money… more>>
HHS/OIG Deputy Inspector General Gary Cantrell testified earlier this year that States are failing to report all of the adverse actions taken by their Licensing Boards. He suggested that the “manner and time of the [reported] notices” are unreliable. Cantrell attributed these concerns to the “voluntary” nature of State reporting obligations.[1] I. The Impact on Exclusion… more>>
I. Take It from CMS: If You're Excluded in One State, You're Excluded in All States Section 6401(b)(2) of the Affordable Care Act (ACA) required the Centers for Medicare and Medicaid Services (CMS) to create a national database where State agencies could share and access information about individuals and entities that were terminated from the… more>>
I. Provider Self-Disclosure Protocol: New Guidance Sheds Light on Disclosure On April 17, 2013, the Office of the Inspector General (OIG) issued an updated Provider Self-Disclosure Protocol that many viewed as an attempt to make the process somewhat more “user friendly.”[1] Regardless of whether that was the aim – or if it was achieved to some extent –… more>>
In May 2014, the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services published two proposed rules to implement provisions of the Affordable Care Act (ACA). The new rules add and expand upon OIG’s current exclusion and Civil Monetary Penalty (CMP) authority. I. Revisions to OIG's Exclusion Authority The new… more>>