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Healthcare Outsourcing: Avoiding OIG Exclusion & Debarment Penalties

In order to succeed in today's healthcare environment, healthcare organizations of all sizes are increasingly relying upon leveraging expertise from third party vendors, consultants, and services to save costs and gain efficiency. Vendors range from clinical and patient care services, dialysis, diagnostic imaging, pathology review, IT services, EMR platforms, food services and a plethora of other administrative and support services. In fact a recent survey conducted by the national healthcare law firm Waller Law in conjunction with Modern Healthcare Insights found that 98% of respondents reported that outsourcing one or more patient care/clinical services was a normal part of their daily business. The survey also found that this trend was expected to continue over the next 2-3 years. 

OIG Review of State Medicaid Fraud Control

The OIG recently recently its 2012 review of the Louisiana State Medicaid Fraud Control Unit.  Among other findings, the review found that 14% of sentenced providers were not referred to the OIG for exclusion within the appropriate time period ("30 days or other reasonable time period" according to Performance Standard 8(d)).  These providers were not reported to the OIG until after the review.

Nursing License Verification When Doing Business Across State Lines

In today's mobile society many healthcare professionals reside in one state (home state) and travel to or practice in multiple (neighoring states). Since a majority of these professionals are Nurses, many states have signed on to the Nurse Licensure Compact, which enables multistate licensure for nurses.  The question is: When is a License not a License?  By that we mean, when does the fact that a Nurse has a license in his/her home state, but practices in a neighboring state, not meet state licensing laws/requirements? 

Proper Certification Deemed as Important as Healthcare License Status

How important is it to make certain your billing staff is properly trained and certified (ie.CPR, ACLS, CPC and RHIT certifications current)?  Very important. If you are like most healthcare organization you will have internal requirement policies for each department. The purpose of these requirement policies are to ensure that employees are properly trained, certified, licensed and/or maintain sufficient continuting education and training.  Without these minimum documentation, your organization is open to potential litigation, inconsistencies and possible accreditation issues in concern with the healthcare license. 

Does Employer need Employee Permission to Monitor for OIG Exclusions?

Employers have an initial Release and Authorization to conduct a pre-employment background check upon hire.  A proper Release will contain additional language that allows the employer to conduct additional searches "during the scope of the employee's tenure" with the company.  The employer is allowed to conduct additional searches without obtaining a new release in the event of a substantiated inquiry into fraud or other illegal activity.

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