Exclusion screening for nephrology practices and dialysis facilities
Since 2023, two dialysis providers and a nephrology practice have paid $340,241 in OIG exclusion settlements. In the one case where OIG named the excluded person’s role, it was the facility’s social worker. We screen your physicians, clinical team, and office staff every month against the federal exclusion lists and every state Medicaid list, and our specialists resolve any match before it reaches you.
Why dialysis and nephrology are exposed
- Medicare pays for most of your patients. People with end-stage renal disease can qualify for Medicare at any age if they, a spouse, or a parent have enough Social Security work history. Most dialysis patients are on Medicare, which makes most of your claims federal claims.
- The care team is wider than nursing. Medicare requires every dialysis facility’s care team to include a social worker and a dietitian alongside nurses and physicians, and facilities also employ patient care technicians. In 2023 Global Dialysis Plus in Texas paid $20,000 because its excluded social worker furnished services billed to federal programs.
- Nephrologists work in more than one place. A nephrologist may see patients in the practice, round at several units, and serve as a medical director. Each organization that bills for that work needs its own screening record.
Who to screen
- Nephrologists, NPs, and PAs, including medical directors and physicians who round at your units
- Dialysis RNs and LPNs, including home dialysis training nurses
- Patient care technicians, including per diem and agency staff
- Social workers and dietitians
- Biomedical and water treatment technicians
- Front desk staff, schedulers, billers, and coders
- Owners, joint venture partners, and management company staff
The group dialysis providers forget most often is social workers and dietitians. They don’t run machines, so they can sit outside the clinical screening process. The Global Dialysis Plus case shows OIG counts their work.
“We really appreciate how responsive and thorough you’ve been throughout this process.”
Valene Cook, Lindsay Municipal Hospital
About 1,000 healthcare organizations trust us with their screening every month, including many nephrology practices and dialysis providers. Exclusion Screening was founded by former federal prosecutors Paul Weidenfeld and Robert Liles.
How we handle dialysis and nephrology screening
- Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, across every unit and practice location.
- Identity verification before anything is flagged. We confirm identity with Social Security number, date of birth, NPI, or license data before calling something a match.
- Our specialists resolve matches. When a name comes back, one of our trained specialists works it to a conclusion. Your facility administrator doesn’t have to research possible hits.
- Dated records for every person, every month, ready when a surveyor or auditor asks to see your screening history, including for staff who have left.
Plans start at $30 a month for up to 100 people. See pricing or schedule a demo.
What the rules require of dialysis facilities and nephrology practices
OIG’s Civil Monetary Penalties Law. An organization that submits claims for items or services furnished by an excluded person is liable if it “knew or should have known” the person was excluded. A screen would have shown it, so not knowing is no defense. “Furnished” covers clinical, support, and administrative work, whether billed separately or bundled.
Contracting counts too. Contracting with an excluded person carries a penalty of up to $24,947 per violation, so agency technicians and contracted physicians belong on your roster. Delegating the screening doesn’t transfer the liability, as we explain in why your staffing agency’s screening is not your defense.
State lists still matter. Many dialysis patients are covered by Medicaid as well as Medicare, and a person can be excluded by a state Medicaid program without appearing on the federal list. See gaps in OIG and state exclusion lists.
What it costs when screening fails
Our Beyond the Checkbox report doesn’t track dialysis or nephrology as its own sector.
OIG settlements with dialysis providers and nephrology practices:
| Year | Organization | Excluded person’s role | Paid |
|---|---|---|---|
| 2025 | Eastern Nephrology (North Carolina) | Not stated (self-disclosed) | $81,561 |
| 2024 | Southeastern Renal Dialysis (Iowa) | Not stated (self-disclosed) | $238,680 |
| 2023 | Global Dialysis Plus (Texas) | Social worker | $20,000 |
Sources: OIG enforcement actions (Eastern Nephrology, Southeastern Renal Dialysis, Global Dialysis Plus).
The bill has two parts. The civil money penalty can reach $24,947 per claim in 2026, and every claim tied to the excluded person’s work is an overpayment that must be repaid.
Payer mix is where dialysis differs. For staff who don’t bill, OIG’s Self-Disclosure Protocol estimates the overpayment as salary and benefits multiplied by your federal payer mix. Beyond the Checkbox uses a 50% mix in its example. A dialysis facility’s mix is usually far higher. A social worker costing $60,000 a year at a facility where 90% of revenue is federal works out to a $54,000 overpayment for each year of employment. For facilities that self-disclose, as Eastern Nephrology and Southeastern Renal Dialysis did, settlements generally start at a 1.5x multiplier. When the government finds it first, the False Claims Act allows treble damages, and OIG is not bound by the proxy.
Common dialysis and nephrology screening mistakes
- Screening only nurses and technicians. Social workers, dietitians, and biomedical techs furnish services too.
- Assuming the practice or the unit has the physician covered. A nephrologist who works in both should appear on both organizations’ rosters.
- Screening at hire and not again. Exclusion lists update monthly. More on why monthly screening matters.
- Trusting agency attestations for PCTs. Without dated, per-person results for each agency technician, you can’t show you met the “should have known” standard.
A screening program for a dialysis facility or nephrology practice
- Build your rosters. Include employees, agency staff, rounding physicians, contractors, and owners. Give each dialysis unit its own roster so it gets its own report. Units are often audited one at a time.
- Screen before the first shift. Check the federal lists and the Medicaid list of every state where you bill.
- Re-screen everyone monthly. Monthly is the floor.
- Coordinate with partners. If a practice and a dialysis company share physicians, agree on who screens whom.
- Resolve every match the same week. Confirm identity, document the outcome, and pull the person from patient care and billing if the match is real.
- Keep dated records and a response plan. Store results per person, per month. See what to do if you have a confirmed exclusion. Larger medical groups should also see exclusion screening for physician practices.
Questions dialysis and nephrology compliance teams ask
Do we need to screen social workers and dietitians?
Yes. OIG’s rule covers anyone who furnishes items or services to federal program patients, including support and counseling work. Global Dialysis Plus paid $20,000 in 2023 because its excluded social worker furnished services billed to federal programs. Screen social workers and dietitians on the same monthly schedule as your nurses and technicians.
Why does payer mix matter so much for a dialysis facility?
When OIG estimates the overpayment for staff who don’t bill, it multiplies their salary and benefits by your federal payer mix. A facility that gets most of its revenue from Medicare and Medicaid counts most of an excluded employee’s pay as overpayment, before any multiplier. The same mistake costs a dialysis unit more.
Our nephrologists are screened by the practice. Does the dialysis unit need to screen them too?
Each organization that submits claims tied to the physician’s work carries its own liability, and each needs its own record. The simplest approach is for the dialysis unit to put every rounding physician and medical director on its own monthly roster, or to get dated, per-person results from the practice every month.
How often should a dialysis facility screen?
Monthly, plus before anyone’s first shift. Exclusion lists update monthly, and the “knew or should have known” standard means a check you could have run counts against you. Dialysis patients are treated on a recurring schedule, so a gap of even a few months covers a lot of treatments, and nearly every one is a federal claim.
See SAFER Plus screen a dialysis roster: every unit and rounding physician, every state list, matches resolved by our specialists. Schedule a demo →