OIG Exclusion List Checks

oig exclusion list check

Automate Monthly Federal Exclusion List Searches

Check the OIG exclusion list, System for Award Management (SAM), and the GSA EPLS debarment list.
 


The Federal mandate states, "If you are excluded in one state, you are excluded in all states," creating a lot of work for HR and compliance departments.

Why ProviderTrust Is Better For Exclusion List Checks.

ProviderTrust tackles this workload by checking every exclusion list from the OIG LEIE to the 33 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.

Why Perform Monthly Exclusion Checks?

Effective March 25, 2011 within the Affordable Care Act, CMS recommended states require monthly checks of the OIG LEIE exclusion list for all employees and providers involved in providing healthcare 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. Now, 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: 

Mandatory Exclusions:

  • Medicare or Medicaid fraud
  • Patient abuse or neglect
  • Felony convictions relating to unlawful production or dispensing of controlled substances

Permissive Exclusions

  • Misdemeanor fraud of publicly funded programs
  • Misdemeanor convictions relating to unlawful production, or dispensing of controlled substances
  • Suspension, revocation, or surrender of a healthcare license for reasons or unprofessional conduct
  • Submission of false or fraudulent claims
  • Engaging in kickback arrangements
  • Defaulting on a health education loan

Federal (OIG Exclusion List) vs. State Exclusion Lists

The most common question we hear is: "Is checking my facilities' state Medicaid exclusion list and the OIG exclusion list enough?" 

The short answer is: No. You should check all federal and state exclusion lists because the employee or provider may fail to disclose past address history. 

In addition to the federal exclusion lists, there are currently 33 states including the District of Columbia maintaining Medicaid exclusion lists. The following is a list of those states (highlight indicates linked exclusion list):

  1. Alabama
  2. Alaska
  3. Arizona
  4. Arkansas
  5. California
  6. Connecticut
  7. District of Columbia
  8. Florida
  9. Hawaii
  10. Idaho
  11. Illinois
  12. Kentucky
  13. Louisiana
  14. Maine
  15. Maryland
  16. Massachusetts
  17. Michigan
  18. Minnesota
  19. Mississippi
  20. Missouri
  21. Nebraska
  22. Nevada
  23. New Jersey
  24. New York
  25. North Dakota
  26. Ohio
  27. Pennsylvania
  28. South Carolina
  29. Tennessee
  30. Texas
  31. Washington
  32. West Virginia
  33. Wyoming

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!

Exclusion List Check Best Practices

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.

  • Search with first initial only
  • Request and search all previous last names
  • Search variations of commonly altered names (ex. Beth for Elizabeth)
  • Refer to background checks completed for additional names to search

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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