Since the CMS Preclusion list was announced in April 2018, and then published in January 2019, there has been confusion and questions regarding the list, its differences from the OIG Exclusion List, the size of the list, and who has access. Unfortunately, the publication of the list has added further complexity to the already complicated… more>>
What is the Length of a Mandatory Exclusion?(January 8th, 2021): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) is responsible for overseeing the financial and program integrity of more than 100 HHS programs, one of which is the Medicare program. As you would imagine, the Medicare program is quite costly. … more>>
(December 22nd, 2020): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) exercises both mandatory and permissive exclusion authority with respect to Federal health care programs.[1] In a recent New York case, the OIG was required by law to mandatorily exclude an individual for a minimum of five years due to… more>>
Why is it Necessary to Screen Against the NPPES Registry? (December 7th, 2020): We are sometimes asked “Why do you screen against the National Plan and Provider Enumeration System (NPPES).” That is a great question. Many health care providers are only familiar with the exclusion database maintained by the Department of Health and Human Services (HHS),… more>>
Exclusion Actions Under 42 U.S.C. § 1320a-7(b)(5)(B) (November 2020): Since 1976, the Department of Health and Human Services (HHS), Office of Inspector General (OIG) has been at the forefront of our nation’s efforts to fight waste, fraud and abuse in the Medicare, Medicaid and more than 100 other programs. Collectively, the costs of the federal programs… more>>
A State Conviction for “Patient Neglect” Will Result in Mandatory Exclusion from Participation in Federal Health Benefit Programs (March 27, 2020): The Department of Health and Human Services (HHS), Office of Inspector General (OIG) may be required by law under Section 1128 of the Social Security Act to exclude individuals and entities from participating in Federal… more>>
After finding a confirmed exclusion among your employees, vendors, contractors, or volunteers there are several options you can take. Each case with a confirmed exclusion is fact-specific, there is no “rubber-stamp” approach to this problem. This article discusses and outlines possible paths that can be taken by entities after finding a confirmed exclusion. I. Review of… more>>
Massachusetts Medicaid Exclusion Screening:Requirements and Best Practices for Compliance The Massachusetts Medicaid Exclusion requirements, under MassHealth, will not reimburse any item or service furnished directly or indirectly by individuals or entities that have been excluded from any State or Federal health care programs. This broad “Payment Prohibition” is enforced by the Massachusetts Executive Office of Health… more>>
Federal Exclusion Regulations and Enforcement Authorities, and How Providers Can Avoid Risk with Proper Exclusion Screening OIG background check –Part 2Paul S. Weidenfeld, JDThis article was originally written by Paul Weidenfeld and published by GreenBranch Publishing. This article is Part 2 from a 2-Part article originally published by GreenBranch Publishing on their website.Office Inspector General… more>>
The complex web of regulation encompassing government health care dollars is a lot to take on. With 41 state exclusion lists and several federal lists, it can be difficult to know which exclusion lists to screen, let alone actually screening them all. Each government payor of healthcare dollars has a different set of rules on… more>>