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OIG's monthly exclusion list update

Posted by: Robert Markette
March 05, 2008
Topic: Fraud and Abuse, Self Referral, False Claims

OIG has posted its updated exclusion list.  This list contains the full exclusion database and is meant to replace the one issued last month.  You can download it here: updated exclusion list .  

If you have not heard of the exclusion list and you provide any federally reimbursable services, you should probably browse this post: Have you checked the exclusion list lately?

If you did not realize it, the OIG list is updated monthly.  This is because individuals are added to or removed from the list each month.  (I suspect more are added to it then removed from it, but I have never really checked the totals.)

OIG and its counterparts at the various state Medicaid Fraud Control Units recommend checking this list every month.  This is great advice if you have a lot of staff with time on their hands.  (If you are reading this and have such a person, you are either overstaffed or not a home health or hospice company.)  However, for the home health and hospice industry, this is not practical.

Many providers only perform these checks upon hiring. It is advisable to occasionally “recheck”.  How often you recheck can depend upon a number of factors, including number of employees to check and number of staff available.  The bottom line is that if you have an employee who becomes excluded while employed by you (trust me, it can happen), you may end up owing the government a lot of money.  The longer you go between checks, the bigger the check you may have to write.  Of course, the more frequently you check, the greater the burden on you and your staff.  

Ultimately, the important point is that you do perform “rechecks” and do so enough to protect yourself.
         

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