Effect of an Exclusion

The New “Seventh Element” of Compliance: Screening and Evaluating Employee Suitability!

The recently issued Resource Guide for Measuring Compliance Program Effectiveness, reconfigures the traditional formulation of the “Seven Elements of an…

Home Health Final Rule Extends Exclusion Screening Obligation: Failure to Screen Could Result in Termination from Medicare

By Paul Weidenfeld The new Final Rule issued by CMS revising the conditions of participation for home health agencies (HHAs) requires…

Who Is to Blame for Gaps in OIG and State Exclusion Lists? What Is the Impact on Providers?

The failure to report excludable offenses by state Medicaid offices and licensing boards is a longstanding issue for the OIG….

Southern District of New York Provides Clarity on “Identifying” Overpayments

In early August of 2015, the Southern District of New York (SDNY) provided insight as to when the 60-day clock for…

Recent Developments on the 60-day Rule and the Potential Impact on Exclusion Violations

The Affordable Care Act (ACA) creates a 60‑day window to report and return overpayments from Medicare or Medicaid after the…

OIG Issues Advisory Opinion on Exclusions

I.  Advisory Opinion on Payments for Services Provided Prior to Exclusion The Department of Health and Human Services Office of…

Student Loan Default Becoming a Top Reason for Exclusion

Providers are often surprised to learn that a person can be excluded from participation in federal health care programs because…

OIG Provides Guidance on Disclosures for Conduct Involving Excluded Persons in the Updated Self-Disclosure Protocol

I. Provider Self-Disclosure Protocol: New Guidance Sheds Light on Disclosure On April 17, 2013, the Office of the Inspector General…