OIG and Integration

[Raj Nukala]

Hello All

I am interested to know how present day hospitals are using or integrating OIG compliance check. Any companies performing clinical trials are also using OIG Exclusion to not do business with any one on this list ? Appreciate if anyone can share with me the scenarios which call for OIG exclusion list check.

Regards
Raj

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[Marshall Maglothin]

In the U.S., all healthcare providers who do business with DHHS CMS, that is
bill for services to Medicare, Medicaid, Tricare, Retired Railroad, etc or
as you noted are engaged in research that receives any Federal funding, are
required to verify that ALL employees (physicians, RNs, clerks, dietary
aides: ALL) are not on the OIG excluded list.

http://oig.hhs.gov/fraud/exclusions.html

This is fairly fool-proof for physicians since they not only have to be
checked by their malpractice insurer, but are also "credentialed" by each
hospital and every insurance plan -all of whom are required to check the
list and, by contract, and report any excluded provider to the other
parties. All insurance companies' contracts require that they immediately
drop (not pay) any excluded physician.

For all other employees, the process is very simple: at the time of
employment, the person's name is checked against the OIG list which can
either be downloaded or checked on-line: http://exclusions.oig.hhs.gov/

I print a copy of my search for the name when it returns "not found" and
drop it in the new employee's personnel file for compliance documentation.

[snuf...@aol.com]

I am actually aware of a company that has automated this review process and checks for new employees, vendors, etc. to see if they are on this list if anyone is interested.

Regards,

Alan

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[snuf...@aol.com]

I am aware of a company that for a fee has automated and will undertake a review process of those vendors, new employees, current employees, doctors, etc. that may be on this list if anyone is interested.

Regards,

Alan


-----Original Message-----
From: Marshall Maglothin <mmagl...@medaxiom.com>
To: techal...@googlegroups.com
Cc: rajn...@yahoo.com
Sent: Sun, 6 Apr 2008 11:41 am

[Marshall Maglothin]

Well, I suspected this was not an honest inquiry, but some kind of promo.

 

The weblink I provided is the FREE, OFFICAL, U.S.  OIG site:

http://oig.hhs.gov/fraud/exclusions.html

 

 and any large healthcare organization that I have ever encountered simply checks new employees as they hire them.

 

Being “excluded” after being hired is certainly not something that a current employee could hide from the employing organization.

[snuf...@aol.com]

Marshall,

My suggestion is that unless your healthcare entity has a dedicated qualified staff person checking the excluded list daily, the risk to the healthcare entity is very costly if they get caught with some of these excluded people doing work with or for them as seen per regs below:

Per the regs: An excluded party is in violation of its exclusion if it furnishes to Federal program beneficiaries items or services for which Federal health care program payment is sought. An excluded individual or entity that submits a claim for reimbursement to a Federal health care program, or causes such a claim to be submitted, may be subject to a CMP of $10,000 for each item or service furnished during the period that the person or entity was excluded (section 1128A(a)(1)(D) of the Act). The individual or entity may also be subject to treble damages for the amount claimed for each item or service. In addition, since reinstatement into the programs is not automatic, the excluded individual may jeopardize future reinstatement into Federal health care programs (42 CFR 1001.3002).

Finally your assumption with regard to employees not being able to hide their being on a the excluded list from their employing organization assumes that they never work a second job within healthcare.  Additionally, someone also needs to watch all of the vendors doing work with the entity as seen in this statement on the OIG website:

Set forth below is a listing of some of the types of items or services that are reimbursed by Federal health care programs which, when provided by excluded parties, violate an OIG exclusion. These examples also demonstrate the kinds of items and services that excluded parties may be furnishing which will subject their employer or contractor to possible CMP ("civil money penalty") liability.

• Services performed by excluded nurses, technicians or other excluded individuals who work for a hospital, nursing home, home health agency or physician practice, where such services are related to administrative duties, preparation of surgical trays or review of treatment plans if such services are reimbursed directly or indirectly (such as through a PPS or a bundled payment) by a Federal health care program, even if the individuals do not furnish direct care to Federal program beneficiaries;

• Services performed by excluded pharmacists or other excluded individuals who input prescription information for pharmacy billing or who are involved in any way in filling prescriptions for drugs reimbursed, directly or indirectly, by any Federal health care program;

• Services performed by excluded ambulance drivers, dispatchers and other employees involved in providing transportation reimbursed by a Federal health care program, to hospital patients or nursing home residents;

• Services performed for program beneficiaries by excluded individuals who sell, deliver or refill orders for medical devices or equipment being reimbursed by a Federal health care program;

• Services performed by excluded social workers who are employed by health care entities to provide services to Federal program beneficiaries, and whose services are reimbursed, directly or indirectly, by a Federal health care program;

• Administrative services, including the processing of claims for payment, performed for a Medicare intermediary or carrier, or a Medicaid fiscal agent, by an excluded individual;

• Services performed by an excluded administrator, billing agent, accountant, claims processor or utilization reviewer that are related to and reimbursed, directly or indirectly, by a Federal health care program;

• Items or services provided to a program beneficiary by an excluded individual who works for an entity that has a contractual agreement with, and is paid by, a Federal health care program; and

• Items or equipment sold by an excluded manufacturer or supplier, used in the care or treatment of beneficiaries and reimbursed, directly or indirectly, by a Federal health care program.

By the way, I am not sure about your promo comment since I suggested an automation solution based on Raj's request and on the fact that this is a technology group.  Your solution states that you manually check each person one (or up to five at a time) and then manually print the results and put it in the employee's folder as seen in your email below.