Since August 2014, the Office of Inspector General (OIG) has collected roughly $3.75 Million in Civil Money Penalties (CMPs) in cases involving the employment of persons that have been “excluded” from Medicare. This amount exceeds the total CMPs assessed by OIG on…
The Office of the Inspector General (OIG) Broadly Interprets Exclusion Regulations OIG’s Demonstrated Interest in Exclusion Screening and Forewarning of Increased Enforcement Efforts The OIG’s Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs[1] explains the types…
I. Hospital Employed Therapist with Lapsed License The Department of Justice (DOJ) entered into a settlement with a nonprofit Michigan hospital this week resolving allegations that the hospital submitted false Medicaid claims. The services had allegedly been rendered by a therapist with a lapsed license. Further,…
I. Fraud Found in HHS’ Backyard A Virginia contractor for dental providers was recently indicted by a grand jury on charges of wire fraud, health care fraud, identity theft and making false statements relating to health care matters. The contractor’s…
I. OIG Targets Nursing Homes Last year almost half of the exclusion violation matters reported by the Office of the Inspector General (OIG) involved nursing homes and rehabilitation facilities. This trend is continuing. Last month, the OIG reported five new cases on…
I. Excluded Podiatrist Commits Health Care Fraud A Michigan podiatrist who was excluded from participation in the Federal health care programs for a period of 25 years allegedly entered into a health care fraud scheme with another Michigan doctor…
I. Advisory Opinion on Payments for Services Provided Prior to Exclusion The Department of Health and Human Services Office of the Inspector General (OIG) issued an advisory opinion in response to payments received by an excluded provider for services performed prior to the effective date of…
I. CMPs doubled in OIG Exclusion Violations 2014 Exclusion Screening, LLCSM dedicates a significant amount of time to examining the Office of the Inspector General’s (OIG) enforcement actions as they relate to exclusion violations. As a broad overview, in 2014 HHS-OIG imposed $10.54…
I. OIG Report In the Office of the Inspector General’s (OIG) semiannual report to Congress, it claimed credit for excluding 2,297 individuals and entities from Medicare, Medicaid, and other Federal health care programs. The OIG also claimed credit for initiating 506 criminal and 267…
Providers are often surprised to learn that a person can be excluded from participation in federal health care programs because of student loan default. In fact, the failure to repay student loans is one of the most common reasons people find…
The Office of the Inspector General (OIG) issued a Special Advisory Bulletin in May 2013, which states that providers can “avoid potential Civil Monetary Penalty (CMP) liability” simply by checking the List of Excluded Individuals and Entities (LEIE) to “determine…
I. Federal and State Agencies Conducting Audits As many healthcare providers and suppliers have painfully learned over the last year, federal and state law enforcement agencies, along with many of the contractors with whom they work, are actively conducting audits…
I. Civil Monetary Penalties Twenty-five out of the fifty-five exclusion enforcement actions reported in 2014 have occurred in home health, hospice, or nursing and rehabilitation facilities. The Civil Monetary Penalties (CMPs) imposed in these cases range from $10,000 to $428,935…
At Exclusion Screening, LLCSM, we know the ins-and-outs of the exclusion screening process. In our opinion, an effective screening process requires some mandatory tools. To ensure that there are no holes in your screening process make sure you have: A…
I. Mandatory OIG Exclusions When the Office of Inspector General (OIG) considers imposing a mandatory exclusion, it sends the individual or entity a Notice of Intent to Exclude.[1] The Notice includes the reason for the proposed exclusion and the possible effect…
I. OIG Recommends Monthly Screening While there is not a formal regulation that mandates monthly exclusion screening, OIG issued guidance in May 2013, which recommended that providers check their employees and contractors against the OIG-LEIE each month because the LEIE…
A quick review of the Office of Inspector General’s (OIG) exclusion enforcement actions might make one wonder why the Civil Monetary Penalties (CMPs) for some entities are only $10,000 while others are closer to $2,000,000. We were curious as well, and…
I. Florida’s State Exclusion. Excluded Providers Costs OIG Over 2.7 Million The Office of the Inspector General (OIG) recently released a study on a subset of Florida’s Medicaid payments for pharmaceutical items. The study showed that in 2009 and 2010…
HHS/OIG Deputy Inspector General Gary Cantrell testified earlier this year that States are failing to report all of the adverse actions taken by their Licensing Boards. He suggested that the “manner and time of the [reported] notices” are unreliable. Cantrell attributed…
I. Take It from CMS: If You’re Excluded in One State, You’re Excluded in All States Section 6401(b)(2) of the Affordable Care Act (ACA) required the Centers for Medicare and Medicaid Services (CMS) to create a national database where State…
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