In-Depth Articles

Medicare and Medicaid Exclusion Screening Compliance: A Challenging Problem with a Surprisingly Simple Solution©

Since August 2014, the Office of Inspector General (OIG) has collected roughly $3.75 Million in Civil Money Penalties (CMPs) in cases involving the employment of persons that have been “excluded” from Medicare. This amount exceeds the total CMPs assessed by OIG on this issue in all of 2013. This continues an established trend. The number of exclusion… more>>

OIG’s Updated Special Advisory Bulletin on the Effect of Exclusions

The Office of the Inspector General (OIG) Broadly Interprets Exclusion Regulations OIG's Demonstrated Interest in Exclusion Screening and Forewarning of Increased Enforcement Efforts By Paul Weidenfeld The OIG's Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs[1] explains the types of conduct that could violate the payment prohibition, which regards items or services provided… more>>

HCFAC Report 2014: After Consecutive Record Years, Recoveries and Prosecutions Dip, but Exclusions Continue to Increase

The Health Care Fraud and Abuse Control Program1 (“HCFAC”) prepares detailed yearly reports which are sometimes viewed to be a barometer of fraud and abuse enforcement efforts. Valid conclusions can’t be drawn based on small samples or on numbers alone. However, side by side comparisons of data or even over a short period of time may be suggestive… more>>

Why Should I Screen Against Every State Exclusion List?

man overwhelmed by paper - state exclusion list

The Office of the Inspector General (OIG) issued a Special Advisory Bulletin in May 2013, which states that providers can “avoid potential Civil Monetary Penalty (CMP) liability” simply by checking the List of Excluded Individuals and Entities (LEIE) to “determine the exclusion status of current employees and contractors.” This past fall, September – November 2014, OIG… more>>

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