Exclusion News

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.

(July 16, 2018):  Perhaps the most severe administrative sanction available under the Social Security Act stems from the authority of the Secretary for the Department of Health and Human Services (HHS) to exclude individuals and entities from participating in Federal and State health benefits programs.[1]  The Secretary has delegated[2] this authority to the HHS, Office… more>>

Dental OIG Exclusions – A Review of 2017 Actions.

(January 12, 2018):  The Medicare and Medicaid programs are both essential, yet costly health benefit programs sponsored in whole or in part by the Federal government.  With Medicare and Medicaid costing $686 and $368 billion each year, respectively, the government has dedicated experienced investigators, auditors and prosecutors to ferret out incidents of health care fraud and… more>>

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 investigation by their State Medical Board.   Unfortunately, that isn’t always the case.  An average of 4,309 physicians are disciplined each year by state licensure boards around the country.[1]  A recent case aptly illustrates how a… more>>

Significant Recent Trends in Exclusion Case Settlements

By Catalina Jandorf The Office of the Inspector General (OIG) has recently entered into a number of exclusion case settlements tied to skilled nursing facilities and hospitals.  Additionally, there have been several recent investigations targeted towards physician practices.  A rising number of these cases with sizable settlement recoveries highlight an emerging trend to be on the lookout… more>>

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 Effective Compliance Program by making the “Screening and Evaluation of Employees, Physicians, Vendors and other Agents” an element unto itself – or the new “Seventh Element of Compliance!” The Resource Guide, a product of roundtable discussions… more>>

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

By Paul Weidenfeld and Catalina Jandorf The new Final Rule issued by CMS revising the conditions of participation for home health agencies (HHAs) requires that providers “must ensure” that agencies providing services under arrangement have not been excluded from Medicare, Medicaid or any other federal health care program.  Effective July 17, 2017, the rule also states that… more>>

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