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Exclusion, Termination, and the OIG

Enforced by the Office of Inspector General (OIG) in the U.S. Department of Health and Human Services or a state Medicaid program, healthcare sanctions are the result of an administrative hearing where an individual or entity is found to be in violation of an administrative rule, civil law, or criminal offense. An exclusion – mandatory or permissive – is one of several possible results of a sanction, as well as license restrictions, license revocation, suspension, or voluntary surrender of license. Termination, however, occurs when the state terminates the participation of a Medicaid or Children’s Health Insurance Program (CHIP) provider or supplier’s billing privileges and the provider can no longer appeal. The termination is from all states, not just the state in which it occurred. There are several best practices that will help organizations verify appropriate, actionable data from the OIG’s List of Excluded Individuals/Entities (LEIE), including monthly monitoring, the use of any former names in searches, the use of both parts of a hyphenated last name in a search, and the maintenance of documentation of the initial name search performed and any other additional searches conducted in order to verify results of potential name matches, among others.

 

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Post By Ken Shafton (887 Posts)