What happens if an individual is excluded?
If an individual is excluded, then he or she may not directly or indirectly participate in the Federal health care programs. No federal payment will be made for any items or services that are furnished or provided by excluded persons.
What is the liability with excluded individuals and entities?
Any claim tainted with excluded individuals or entities may be liable for penaltes upto $21,562.80. If you fail to report a violation within 30 days, then this becomes a liability under the False Claims Act with potential for upto 3 times the damages.
Does screening for exclusions apply to Medicare or Medicaid only?
You are required to screen your employees vendors, contractors, and even volunteers if you work with ANY government health benefit program. This includes but not limited to: Medicare, Medicaid, VA, CHIP, Tricare, etc.
Do I need to perform screening against just the OIG list?
Requirements vary from state to state, however, it is in your best interest to screen all of your employees, vendors, contractors, and volunteers against all federal and state databases. Currently this list includes OIG LEIE (list of Excluded Individuals and Entities), GSA SAM (Systems for Awards Management), and approximately 40 state Medicaid exclusion lists.
What is the difference between the OIG-LEIE, GSA-SAM, and the state Medicaid exclusion lists?
The List of Excluded Individuals and Entities is a list of mandatory and permissive exclusion actions taken by OIG which is updated monthly. The System for Award Management (GSA-SAM) includes debarments and sanctions. The state Medicaid lists include providers who have been excluded or terminated from participating in a state’s Medicaid program, which makes them excluded from participating in any state.
Why do I need to check the OIG-LEIE, GSA-SAM, and the state Medicaid exclusion lists?
Currently, states are not required to report exclusions to OIG and there is requirement to share exclusion information between states. Therefore, the OIG-LEIE does not contain all persons excluded under State Medicaid programs and a person who is excluded in one state might and likely will not show up on another state’s exclusion list. However, under ACA section 6501, if a person is excluded in one state, then they are excluded from participating in the Federal health care programs in any state.
Which exclusion databases are included in Exclusion Screening LLC’s services?
At Exclusion Screening, LLC, we think it is critical to screen employees and vendors against OIG-LEIE, GSA-SAM, and all of the state Medicaid exclusion lists currently available.
How often is Exclusion Screening’s exclusion database updated?
OIG-LEIE updates its list monthly, while GSA-SAM and state exclusion lists vary. We automatically update our lists and sync up with the source. All databases are monitored daily and updated within our SAFER exclusion screening platform within a week to ensure that our clients’ employees, vendors, and contractors are screened against the most up-to-date databases.
May I have multiple users?
Absolutely! While there are some restrictions on number of users for the self-service packages and plans, we offer unlimited number of user licenses and logins as needed.
Do I need to verify my own “hits”?
Unlike other exclusion screening companies, we do all the work for you from assisting you with formulating your screening list to verifying any potential hit we discover. If you signed up to our self service BASIC or ESSENTIAL package, you are responsible for performing verification of all potential matches. SAFER provides the management tools to capture your notes as you review and verify these potential matches.
Where do I upload my employee and vendor lists?
All of our premium customers have access to the Exclusion Screening Client Portal to upload the data. You can download the standard upload template and populate the data. Alternatively, we can assist in preparing this list or directly extract data from your IT systems. If you are a self-service customer who signed up to our ESSENTIAL package, you may upload the list directly to SAFER system.
How often may I update my Exclusion Screening list?
As often as you need to! You will have access to your employee list at all times and may update it anytime at no additional charge. If you do not have changes to your list on any given month, SAFER will automatically screen and verify using your most recent list you uploaded.
Can I screen an employee if they are hired in the middle of the month?
Of course! You can use SAFER system to screen any new-hire of even before you offer employment You may also use SAFER to perform similar search on any entity you engage with. There is no additional cost to performing new-hire searches.
How often should employees and vendors be screened for exclusions?
At Exclusion Screening, LLC, we, along with OIG, strongly recommend screening employees upon hire and on a monthly basis going forward.
What is OIG’s Administrative Process for Implementing Exclusions?
OIG’s administrative process is governed by the Social Security Act’s implementing regulations.
What should I do if I receive a positive confirmation from Exclusion Screening?
We recommend ending the relationship immediately and contacting legal counsel.
What is a waiver?
Waivers are only available in certain situations, like if the excluded provider is the only physician in the area or he or she is the only person in a community who is able to offer a certain form of specialized care. Waivers must be requested by the administrator of a Federal or State health program.
When a waiver is granted payment is permitted under Medicare, Medicaid, all Federal health programs within the scope defined by the waiver.
How does someone get reinstated after an exclusion period?
Excluded individuals must apply for reinstatement by sending a written request to OIG and filling out Statement and Authorization forms provided by OIG. This request may be submitted 90 days before the end of the exclusion period.