Why do you need to check your state and Federal exclusion lists?
In January 2023, the Office of the Inspector General (OIG) collected over half-a-million dollars in Civil Monetary Penalties (CMP) from three health care organizations that employed individuals who were excluded from participating in any Federal health care program. These and other Enforcement Actions can be found here.
Individuals or entities can be excluded for a variety of reasons, including conviction for Medicare and/or Medicaid fraud. “Those that are excluded can receive no payment from Federal health care programs for any items or services they furnish, order, or prescribe.” Individuals and entities should be checked against the List of Excluded Individuals/Entities (LEIE) prior to hire/contracting and then ongoing on a monthly basis. The LEIE has an online searchable database or a downloadable database. Monthly updates provide additional exclusions, reinstatements, and corrections to the database.
Additionally, organizations who participate with Medicare will also want to check SAM (System for Award Management) which can be used to “identify a party excluded from receiving federal contracts, certain subcontracts, and certain types of federal financial and non-financial assistance and benefits. Exclusions are also referred to as suspensions and debarments.”
- For more information about the OIG’s Exclusions Program and to access the LEIE databases, click here
- The SAM exclusion list can be checked here
Remember, you should also check your state’s Medicaid exclusion list to ensure that you are not doing business with an individual or entity who has been excluded.
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