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Frequency Of OIG Screening

Question: In addition to prior to hiring, how often does my organization need to conduct excluded parties screening?

Response & Analysis:

Monthly. In the “Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs” (the “SAB”), issued May 8, 2013, the U.S. Department of Health and Human Services Office of Inspector General (the “OIG”) provided specific guidance to the healthcare industry on the frequency of screening employees and contractors to determine whether they are excluded persons. While noting that there is no statutory or regulatory requirement to check the OIG’s List of Excluded Individuals and Entities (the “LEIE”), and that providers may decide how frequently to check it, the OIG affirmed that it updates the LEIE monthly, “so screening employees and contractors each month best minimizes potential overpayment and CMP liability.”

In addition, in a Jan. 16, 2009 letter, the Center for Medicare and Medicaid Services (“CMS”) instructed state Medicaid directors to “require providers to search the HHS-OIG website monthly.” The letter goes on to say that “states should advise providers of their obligation to screen all employees and contractors to determine whether any of them have been excluded.” In 2011, CMS issued final regulations mandating states to screen all enrolled providers monthly.

In addition to the OIG’s federal-level LEIE, 34 states currently maintain their own list of excluded parties. Individuals or entities appearing on such lists are specifically excluded from participation in state Medicare or Medicaid-type programs, such as Medi-Cal in California. These states have specific requirements for searching not only the federal OIG LEIE, but their state-level excluded parties list, as well.

The states’ lists of excluded parties are separate and distinct from the federal list. A comparison of excluded parties at the federal and state levels reveals that while there is some overlap, many excluded parties appear only on one list or the other, rather than both lists. For example, an individual or entity appearing on the Texas list of excluded parties does not necessarily appear on the federal list, and vice versa. As a result, it is recommended that providers search both the federal list and the various state lists.

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This document and/or presentation is provided as a service to our customers. Its contents are designed solely for informational purposes, and should not be inferred or understood as legal advice or binding case law, nor shared with any third parties. Persons in need of legal assistance should seek the advice of competent legal counsel. Although care has been taken in preparation of these materials, we cannot guarantee the accuracy, currency or completeness of the information contained within it. Anyone using this information does so at his or her own risk.

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