Why check for OIG exclusions?
The HHS OIG and Centers for Medicare and Medicaid Services (CMS) expect you to monitor your employees and vendors each month for exclusions. The fines for an excluded provider submitting a bill to CMS can be up to $20,000 per item claimed, plus treble damages. Once an individual or entity is excluded, he/she/it is considered excluded in all states (PPACA 6501).
Don’t forget about your vendors!
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3 reasons why you’ll love using ProviderTrust for exclusion list checks
Every list gets checked
From the OIG LEIE and SAM to all available state Medicaid exclusion lists, your exclusion searches will be more thorough than ever.
The process is automated
Say goodbye to manual exclusion searching and matching. Once you upload your data, exclusion lists are checked on an ongoing basis, keeping you up to date.
Know when an exclusion is found
If a match has been identified your population, you will receive an email alert and phone call from our client success team to help you figure out your next steps.
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With our search process, you’ll never miss an OIG exclusion again
Using our exclusion search tools, we’ll find every possible match and send only verified results to you for review. You’ll save time while confidently protecting your company from expensive exclusion fines. This tried and true process is successfully monitoring millions of providers and vendors.
1. Upload and monitor
Our onboarding specialists will help you set up and upload your data. The system will check your data against every exclusion list every night, going beyond the recommended monthly checks.
2. Match compilation
As your data is being monitored, the system compiles matches from the OIG exclusion list, as well as all other state Medicaid and federal exclusion lists.
3. Match verification
Once potential matches are compiled, our team will review the list to determine if any of the results are exact matches for the individuals or entities you are monitoring.
4. Real-time notification
If a match is found, it will immediately be reflected in your ProviderTrust dashboard and you will receive an email and phone call from our team.
Automate your exclusion checks today
Why wait? Take the next steps to making your job easier, more efficient, and better than ever. Get in touch to demo our software, get pricing, or just introduce yourself.
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“We are very much a government paid company, and it requires us to make sure we do not have anyone excluded. ProviderTrust offers that for us on a very timely basis, and even finds things for us that might potentially be a problem before it becomes a problem.”
Everything you want to know about OIG exclusion list checks, state Medicaid exclusions, and more! Have a question that’s not listed? No worries, contact us here.
Who do I need to monitor for OIG exclusions?
PPACA and new compliance regulations related to exclusions require that you monitor your employees along with the vendors in your supply chain who provide the goods and services your organization relies on to do business.
The May 8, 2013 OIG Special Advisory Bulletin recommends monthly OIG exclusion checks on all entities and vendors.
What causes exclusions?
An individual or entity can be excluded for a variety of reasons. There are two categories these exclusions fall into:
Medicare or Medicaid fraud, patient abuse or neglect, felony convictions relating to unlawful production or dispensing of controlled substances.
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 arrangement; defaulting on a health education loan.
What are some best practices for exclusion list checks?
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. We suggest:
- 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 healthcare 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 your process for checking new hires as well as current employees on a continuing basis.
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 different 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.
What lists do I need to check? What is the difference between the federal (OIG exclusion list) and 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.
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!