Check the OIG exclusion list, System for Award Management (SAM), and the GSA EPLS debarment list.
The Federal mandata states, "If you are excluded in one state, you are excluded in all states," creating a lot of work for HR and compliance departments.
ProviderTrust tackles this workload by checking every exclusion list from the OIG LEIE to the 27 state Medicaid and Medicare exclusion lists in order to find every possible excluded provider, employee and vendor in your organization’s workforce.
Be alerted only when we find one of your employees, providers, or vendors on one of the exclusion lists: OIG exclusion list, GSA EPLS, SAM, and state Medicaid exclusion lists.
Effective March 25, 2011 within the Affordable Care Act, CMS recommended states should require monthly checks of the OIG LEIE exclusion list for all employees and providers involved in providing health care services for an organization billing Medicare and Medicaid.
In the past, multiple federal exclusion lists have existed in differing forms including the OIG, LEIE, GSA EPLS, etc. An increasing number of states maintain Medicare exclusion lists.
As of this past November, the federal government started to work on combining federal exclusion lists into one dataset called SAM (System for Award Management). The EPLS system was retired on November 21, 2012.
According to the HHS/OIG website, exclusion lists exist to prevent individuals and vendors from participating in providing services to healthcare organizations (as an employee, provider, or vendor) billing Medicare or Medicaid for services provided for both mandatory and permissive reasons:
The most common question we hear from clients is: "Is it sufficient to just check the state Medicaid exclusion list where my facility is located in addition to the OIG exclusion list?"
The short answer is: No. You should check all the federal and state exclusion lists because the employee or provider may fail to disclose past address history. Our team has co-authored a White Paper on this subject containing what we believe to be best practices. The White Paper includes references to CMS guidelines: OIG Exclusion List Best Practices.
In addition to the Federal exclusion lists, there are currently 27 states including the District of Columbia maintaining Medicaid exclusion lists. The following is a list of those states (highlight indicates linked exclusion list):
With the services offered by ProviderTrust, all Medicare (federal) and Medicaid (state) exclusion lists are checked for each monitored employee, provider, and vendor automatically on a continuous basis. Let our team do the work for you!
Here at ProviderTrust, we see many instances where our clients have conducted an OIG exclusion list search on an employee and missed an exclusion because the search was conducted too narrowly to catch the individual’s name as it was listed on the OIG exclusion list or Medicaid exclusion list.
Finally, if you have any reason to suspect an employee may be on the excluded parties list, request a letter of proof from the employee provided by the OIG or the state Medicaid agency documenting that there is no exclusion.
With all the changes in health care regulations, it is hard to keep up. Don't forget to update corporate policies and procedures for OIG exclusion list checks and for your corporate policy on checking state maintained exclusion lists. Both of these exclusion list check policies should include both instances of new hires and for current employees on a continuing basis.
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