How Often Should Exclusions Lists Be Checked and Why?

Jun 14, 2018

How often should exclusion checks be done?

The OIG recommends that Exclusion checks are performed prior to employment and on at least a monthly basis after. Individuals/entities are added and removed from the Exclusion list on a daily basis.

 

Atlas Certified technology provides automated initial verification and monitoring with notifications to minimize time and human error associated with completing checks like Exclusions Lists.

 

What is the OIG’s LEIE?

The Office of Inspector General (OIG) provides a List of Excluded Individuals/Entities. This list provides the public with information on the individuals and entities that are excluded from Medicare, Medicaid, and other Federal health care programs.

 

Individuals and entities are placed on the List of Excluded Individuals/Entities for various reasons, including fraud, patient abuse/neglect, license revocation, program-related convictions and more. Depending on the circumstance of exclusion, some individuals/entities have the ability to be reinstated. Once an individual/entity is reinstated, their name is removed from the exclusions list.

 

37 States also provide State based Exclusions Lists. Each list is distributed by the individual state. These lists should be checked in addition to the OIG’s LEIE.

 

What is the scope of the LEIE?

Individual and entities placed on the LEIE are excluded from participating in all Federal health care programs. Federal health care programs include Medicaid, Medicare, and any other health care program that is funded directly or indirectly by the United States, or provides health benefits funded directly or indirectly by the United States.

 

The federal government will not compensate any services or items provided by any individual or entity on the Exclusions List. This includes payment to anyone who employs or contracts an excluded party, or any hospital the excluded party provides services to.

 

 

Who should Providers screen?

Providers should screen the following before contracting services:

  • Employees
  • Contractors
  • Volunteers
  • Board Members
  • Referring Physicians/Practitioners
  • and any other individual working on the behalf or closely with Provider

 

 

What are the consequences?

Organizations suffer both financial and criminal consequences by working with a party that the Provider knows or should know is on the Exclusions List.

 

Financial consequences include fines up to $10,000 for each service or item provided by the Excluded party.

 

Criminal consequences include denying reinstatement to Federal health care programs and criminal liabilities.

 

In May 2018, a Massachusetts Mental Health Center was sued for employing “Unlicensed Staff”

 

What is the best way to stay on top of Exclusion Checks?

Atlas Certified has modernized the process of credential verification by developing an automated system to verify and monitor represented credentials, with historical record and primary source screenshot. By creating a single platform for all verification, organizations can verify and monitor Physician license, Nursing license, NPI Registry, DEA License, and both OIG and State Exclusions Lists all in one place.

 

Read Atlas Certified’s 2018 Must-Read DSCSA Resource Guide.

 

 

 

Resources:

(1) https://oig.hhs.gov/faqs/exclusions-faq.asp

(2) https://www.nhpco.org/education

 

Get Started With Atlas

Smart Screening, Intelligent Hiring, Proactive Alerts, Effective Compliance and Peace of Mind.