Effect of an Exclusion

Why is it Important to Screen Against the GSA’s SAM Database?

(January 16, 2024):  The importance of screening employees, vendors and contractors against available federal and State exclusion databases cannot be…

Resolving Exclusion Violations through the OIG Self-Disclosure Protocol

I. Introduction The Office of Inspector General (OIG) has the authority to exclude providers from participating in federal health care…

Medicare / Medicaid Providers Beware: A Nolo Contendere Plea to a Non-Health Care Crime Can Still Result in Exclusion from Medicare

The last two years have been rough for everyone, and it has been particularly difficult for healthcare providers and suppliers….

The Proposed Expansion of CMS’ Revocation Authority Makes Monthly Exclusion Screening of ALL Employees More Important than Ever!

The Centers for Medicare and Medicaid Services (CMS)[1] is the Federal agency tasked with the overall responsibility of managing the…

When an Underlying Misdemeanor or Felony Conviction is Expunged, Does That Extinguish an Exclusion Action?

Medicare and Medicaid providers / suppliers are prohibited from employing individuals who have been excluded from participation in Federal health…

A State Conviction for “Patient Neglect” Will Result in Mandatory Exclusion from Participation in Federal Health Benefit Programs 

The Department of Health and Human Services (HHS), Office of Inspector General (OIG) may be required by law under Section…

I Have a Confirmed Exclusion What are my Options

After finding a confirmed exclusion among your employees, vendors, contractors, or volunteers there are several options you can take. Each…

Can a Medicare Provider or Supplier Hire an Excluded Individual or Enter in a Contract with an Excluded Entity on the Medicare Exclusion List?

Should you choose to participate in the Medicare and/or Medicaid programs, you must comply with a wide variety of program…

Health Care Providers Should Consider the Ramifications of “Taking a Plea” in a Criminal Case or Agreeing to a Licensure Action. It May Trigger a Mandatory or Permissive OIG Exclusion Action.

Perhaps the most severe administrative sanction available under the Social Security Act stems from the authority of the Secretary for…

Reciprocal Licensure Actions Can Lead to Medicare Revocation and Exclusion

(January 8, 2018):  Most physicians will progress through their entire career without ever having to respond to a complaint or…