Colleton Software is sending out this email as a reminder that it is important you check the OIG Exclusion list prior to hiring or doing business with individuals or entities/vendors to assure they are not included on the OIG Exclusion list. Below I have attached a website where you can search the OIG database.
What is an Exclusion and Why Should You Care?
An exclusion is an administrative action taken against an individual or entity/vendor by the Dept. of Health and Human Services, Office of Inspector General (OIG). The OIG is in charge of enforcing exclusions against individuals or entities. The OIG mandates that healthcare organizations do not hire or do business with “excluded or sanctioned” individuals or entities/vendors. If an individual or entity/vendor is excluded, he/she/it is prohibited from participating in reimbursements for or from federally funded healthcare programs (CMS- Medicare, Medicaid).
Once an individual or entity/vendor is excluded, he/she/it is considered excluded in all states, not just the one excluded in. In other words, under the Affordable Care Act, an individual or entity/vendor excluded in one state is not permitted to participate in federal health care funds in all other states. A person or entity can be excluded by a federal agency (OIG) or by a state Medicaid agency.
What are the penalties for allowing services to be performed by and billed to CMS by an excluded individual or entity?
Civil fines and monetary penalties can be assessed by the OIG. They include the following:
- $10,000 per each item claimed or services provided
- Treble (3 times the amounts claimed to CMS for reimbursement) damages
- Possible program exclusion of the company
- Possible loss of the right to bill CMS for services rendered
- Possible additional fines for filing false claims under False Claims Act (Penalties up to $11,000 per claim, and possible placement in a Corporate Integrity Agreement with the OIG).
- Possible criminal fines and/or jail time.
Web sites to visit: