OIG Exclusion List
We have been taught for years do not employ an individual who is on the exclusion list. When reading it may seem that only providers can be excluded. If you read further into OIG’s frequently asked questions and other clarification OIG provides; there are reasons why staff members can be excluded as well.
How can a staff member be On OIG’s excluded list?
- Key staff members can be also excluded because of an OIG investigation which results in the healthcare professional becoming excluded. In short, they worked in an office where there was fraud, and they were involved. Of course, they will not freely tell you this when you hire them.
- Staff members and providers may also be excluded if they have defaulted on a federally funded student loan.
What do you do? All practices should check the OIG’s List of Excluded Individuals/ Entities (LEIE) whenever you hire a new employee. This list should be checked monthly for all employees, document their status and file in the Compliance Manual. Action should be taken should any employee appear on the list as there are fines and services are not payable to entities that employ excluded employees.
Breakthrough Coaching has systems and forms to make this process easy.