Hi Misty,
The Effect of Exclusion From Participation in Federal Health Care Programs (https://oig.hhs.gov/exclusions/effects_of_exclusion.asp), which was updated in 2013 ,offers some guidance. It states "In order to avoid potential CMP liability, the OIG urges health care providers and entities to check the OIG List of Excluded Individuals/Entities on the OIG web site (www.hhs.gov/oig) prior to hiring or contracting with individuals or entities. In addition, if they have not already done so, health care providers should periodically check the OIG web site for determining the participation/exclusion status of current employees and contractors."
From a best practices standpoint we recommend pre-employment and monthly reoccurring exclusion monitoring of the OIG-LEIE, other Federal Databases (SAM, FDA, etc) and State Medicaid Exclusion listings. This should be for all of your employees, vendors and even referring providers. Obviously doing this many checks would be prohibitive and thus technological solutions available in the marketplace make this process less burdensome.
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David Monaghan, MHA
Billingology & Compliatric
Salt Lake City UT
(801) 243-6723
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Original Message:
Sent: 07-23-2018 14:08
From: Misty Birch
Subject: Exclusions Database
Could anyone provide me with how often the Medicare Exclusions Database is to be performed on employees & Providers? We have some that feel it is every 30 days, and others that state annually.
Also, I am in Texas and am being told the state exclusions are to be checked every 30 days.
Any help you can provide is greatly appreciated as we want to be compliant on this.
Thanks!
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Misty Birch
RRV MANAGEMENT, INC.
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