Employing sanctioned or excluded individuals or vendors can put you and your practice in jeopardy of facing serious penalties. The U.S Department of Health & Human Services Office of General Inspector (OIG) suggest regular reviews and recommends monthly screening of all employees to verify that employed individuals do not appear on the OIG List of Excluded Individuals prior to employment. It is important to adhere to the OIG Exclusion List requirements by ensuring employees are not listed on the EPLS. To further minimize risk of employing a sanctioned or excluded party, healthcare institutions are also utilizing a comprehensive database search called FACIS. Fraud and Abuse Control Information System (FACIS) contains information on disciplinary actions taken by federal, state and more than 800 licensing and certification agencies nationwide.
Frequent, and continuous monitoring will help with compliance and regulatory mandates. It is the OIG Exclusion List policy for organizations to check for debarment, exclusion, or other ineligibility for participation in federally funded health care programs or receipt of federal funds. Organizations also must document effective policies and compliance with such requirements. Sarma can provide you with a complete audit trail for compliance.
The dollar amount in settlements can raise a few eyebrows as examples are shown below. These real cases involve false claims allegations, and employing excluded individuals.
- After it self disclosed conduct to OIG a New York Medical Imaging clinic agreed to pay and estimated $227,000 for allegedly violating the Civil Monetary Penalties Law.
- After it self disclosed conduct to OIG, a Texas family hospital agreed to pay over $1 million for allegedly violating the Civil Monetary Penalties Law. OIG alleged that the hospital billed for post-hospital extended care services using certifications and re-certifications that did not meet applicable Medicare criteria.
A university based healthcare system entered into a settlement agreement with the Office of Inspector General upon allegations that the health system employed individuals who were excluded from participating in any Federal health care programs.
A Florida hospice agreed to pay up to $430,000 for allegedly violating the Civil Monetary Penalties Law. OIG alleged that the hospice employed an individual that it knew or should have known was excluded from participation in Federal health care programs.
Are you taking the proper steps to ensure you meet OIG Exclusion List policies and requirements? Call Sarma for more information to get your facility set up now.
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