OIG Exclusion Check and the Role of HR

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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 OIG exclusion checks for all of your employees, referring physicians, and vendors in addition to monitoring the GSA-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…

Human Resources Compliance Checklist

From the beginning, HR plays a crucial role in ensuring 100% compliance across your organization, particularly with regard to an exclusion check. In an employee’s initial interview, your HR representatives must understand which questions to ask that relate to specific organizational compliance. It’s also imperative that your team conduct a thorough background check which includes searching SAM and all available state exclusion lists, in addition to your initial exclusion check. HR plays a pivotal role in ensuring compliance from the start of an employee’s tenure and ultimately in keeping your company compliant in the long term.

Following the hire of an employee, HR needs to continue working with your Compliance department to ensure monthly SAM, State, and OIG exclusion checks are being performed efficiently and accurately, with timely results on potential exclusions. Having a system of checks and balances between your Compliance and HR departments ensures organizational compliance and keeps each party accountable, making sure your exclusion check is being performed regularly.

In addition to assisting with a monthly exclusion check, your HR department plays two more important roles:

  1. Regular auditing so that your organization can be Joint Commission ready, should they ever come knocking, and
  2. Facilitating compliance during the self-disclosure process, should you discover an excluded provider.


So here’s the takeaway…compliance is not just a department, it’s a mindset that involves every employee in your organization. As a Human Resources professional, you play a pivotal role in ensuring ongoing compliance and protecting your organization’s liability.

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