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What is the OIG Exclusion List?

The OIG Exclusion List is a list of individuals and entities that are prohibited from providing goods or services to providers that participate in federal healthcare programs.

Employers in the healthcare industry, regardless of the size of the healthcare organization, are required to check the OIG Exclusion List before hiring or engaging individuals or entities to confirm that they are not on the list.

Hiring someone who is currently on the OIG Exclusion List can result in severe penalties, including fines, exclusion from federal healthcare programs, and even criminal charges.

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Where Can the OIG Exclusion List Be Found?

Healthcare providers can check the OIG Exclusion List by clicking here:

Search the Exclusions Database | Office of Inspector General (hhs.gov)

 

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What is the Verification Process? 

Upon clicking on the OIG Exclusion List link above, you will see the screen that shows users the different ways of searching the OIG Exclusions Database.

The User will then be prompted to enter a person’s name.  Should they have a popular name, like mine, it will show multiple steps to confirm.

**Please remember, all of the information of excluded individuals are classified as “public knowledge” it is not covered by HIPAA Privacy and Security.  Therefore, it may show the excluded individual’s identifying information, such as date of birth**

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At this point the user should verify the middle initial. Mine is “A” so it’s not me 😊  However, if the employee does have a middle initial “C” and she is a nursing professional, then you would click to print the search result.  At this point you will also click on “Verify.” This allows the user to view more information such as the excluded individual’s date of birth and enter more information such as social security number, which would clearly identify the employee and determine whether or not they were an excluded individual. 

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Why Should Healthcare Clinics/Organizations Search the OIG Exclusions Database?

All healthcare clinics regardless of its size should check the Office of Inspector General (OIG) Exclusions List for several important reasons:

Compliance with Federal Programs: The OIG Exclusions List contains the names, addresses, National Provider Identifier (NPI) numbers (when applicable), and business details of individuals and organizations that have been excluded from participating in federal healthcare programs. These programs include Medicare and Medicaid. By checking this list, providers ensure that they do not engage with excluded entities or individuals.

Billing Restrictions: If an individual or organization is on the OIG Exclusions List, they are prohibited from billing directly for goods or services under federal healthcare programs. Additionally, other healthcare providers participating in these programs cannot acquire goods or services from excluded entities.

Legal Requirement: OIG is legally required to exclude individuals and entities convicted of specific criminal offenses, including Medicare or Medicaid fraud, patient abuse or neglect, health care-related fraud, theft, financial misconduct, and unlawful distribution of controlled substances.

As you can see, it is very important to verify the OIG Exclusions Database prior to making an offer of employment or engaging with a business entity.

In summary, checking the OIG Exclusions List helps healthcare clinics to maintain compliance, avoid engaging with excluded parties, and uphold the integrity of federal healthcare programs. 

 

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article by
Michelle Ann Richards BSHA, CPC, CPCO, CPMA
Owner, Coding & Compliance Experts and OSMA Consultant