ProviderTrust is committed to serving our partners, clients, and friends in a time of need as the Novel Coronavirus spreads across the globe.
Author: David Servodidio
Last night was devastating for the city we love so much. We saw our families, neighbors, and friends face a vicious tornado that ripped through Nashville and claimed the lives of multiple people and destroyed homes and businesses in its path across the region. Nashville is a part of the ProviderTrust story, and we are deeply committed to helping our friends and neighbors rebuild.
So…you're excluded. Your name is posted on the OIG's List of Excluded Individuals and Entities (LEIE), and the exclusion is following you around like a Scarlet Letter wherever you go, preventing you from working for or with any healthcare company that bills Medicare/Medicaid. What exactly is the Process for Excluding Individuals/Entities? The OIG's exclusion process is governed by regulations that implement sections of the Social Security Act. Keep in mind: "When an individual or entity receives a Notice of Intent to Exclude, it does not necessarily mean they will be excluded. The OIG will carefully consider all material provided by the person who recieved the Notice before making a decision." For both mandatory and permissive exclusions the administrative process is the same. The OIG sends out a written Notice of Intent to Exclude which includes the reasons for exclusion and the its effects. Remember, the notice is just a notice and allows the individual 30 days to gather information or evidence on whether or not the exclusion is warranted. Then and only then will the OIG make a final decision on whether or not to grant the exclusion.
It's no secret that performing an OIG exclusion check on a monthly basis is industry best practice and the best way to reduce your organization's overall risk and liability. But what role does your HR department play in ensuring your OIG exclusion check is done most effectively? Your compliance department typically handles ongoing an OIG exclusion check for all of your employees, referring physicians, and vendors in addition to monitoring the SAM dataset and all available state exclusion lists. However, it's really your HR department that plays the single most cohesive role in the process. Here's why…