What is an OIG exclusion check?
Medicare & various other federal and state government organizations have lists of excluded people and entities. The government agencies will not compensate for services provided directly or indirectly by those excluded parties. Simply put, OIG exclusion checks ensure that you don’t charge federal health plans for services provided directly or indirectly by anyone on the OIG exclusion list.
Why is running a check within the OIG necessary?
Generally speaking, exclusion is a payment prohibition. If you do inappropriately charge Medicare/Medicaid for a service provided by an excluded individual or entity, you’ll have to pay it back and you might be subject to fines that increase the liability by up to 300%. Checking for exclusion is a risk management function to ensure you don’t get into that unfortunate situation.
What is a Civil Monetary Penalty (CMP)?
Civil Monetary Penalties impose up to a triple multiplier effect. Civil Monetary Penalties can apply when an organization knew or should have known it was being reimbursed for services provided directly or indirectly by an excluded party. There is a 6 year statute of limitations on Civil Monetary Penalties.
The OIG is the primary enforcement agency, can you give us a brief overview of the OIG?
The Office of Inspector General (OIG) is a division of the Department of Health and Human Services that enforces the List of Excluded Individuals and Entities (LEIE). If an organization is reimbursed inappropriately for services provided by an excluded party, the OIG is the agency who enforces repayment for those services and can apply Civil Monetary Penalties.
What is Self-Disclosure?
If an organization finds that it was reimbursed for services provided by an excluded party, the organization should consider self-disclosure to the OIG. The OIG publishes a self disclosure protocol document on its website that can be very helpful in this regard. Although self-disclosure will not prevent repayment of services rendered by an excluded party, it could significantly reduce Civil Monetary Penalties.
Can Verify Comply™ help prevent CMPs?
The goal is to avoid any enforcement action and avoid getting in a situation where you must pay back federal healthcare dollars. Our software and services can help you make sure your employees, vendors, contractors, etc. are not on federal or state exclusion lists. Additionally, our reports track your OIG checks, should you need to prove due diligence to anyone that you have been performing routine exclusion searches.
Verify Comply™ OIG Exclusion Screening Services
If you're looking for ways to efficiently handle monthly OIG exclusion checks, we offer a range of services that can be tailored to meet your exact needs. If you're not sure what you need, contact us - we'd love to help!
