To answer this question, it is important to understand how the two federal databases relate to each other and how they differ. Common Purpose Both databases were created to promote quality health care for the public and to reduce health...
Referrals from Excluded Providers
January 18, 2021
Hospitals and other health care providers typically rely on referrals from community providers as a major source of patients and revenue. The federal Stark and Anti-Kickback laws strictly regulate provider and facility arrangements related to referrals and kickbacks to maintain...
Differences Between the OIG’s LEIE and GSA’s SAM Exclusion Lists
January 11, 2021
EXCLUSION LISTS DEMYSTIFIED Federal and state exclusion lists abound. There are two primary federal lists, which are addressed in this article, but to there are many other lists that should be considered when screening employees, contractors and potential hires. However,...
COVID-19 Health Care Changes that May Survive the Pandemic
January 4, 2021
The COVID-19 pandemic has changed the face of the health care industry on multiple fronts. These range from the multiple blanket 1135 temporary waivers issued by CMS that control how care for federal program beneficiaries could be delivered and by...
Understanding Waivers & the Duration of OIG Exclusions
December 28, 2020
Exclusion Background As noted in past blog posts, HHS OIG Exclusions are comprehensive and significant. Exclusion from participation in federal healthcare programs can have a profound effect on a provider’s healthcare practice. There are two primary types of exclusions- mandatory...
Survey and Accreditation Activities in the Age of COVID-19
December 21, 2020
As the first vaccines are delivered across the US, we can begin to look forward to a post-pandemic future and resuming routine activities that have been sharply curtailed in 2020. This includes the resumption of the full accreditation and survey...
Pandemic-Related Waivers by CMS and the Continued Importance of monitoring OIG Exclusion Lists
December 14, 2020
COVID 19 has resulted in a flurry of waivers by federal and state regulatory agencies related to the provision of health care for Medicare and Medicaid patients. The CMS blanket waivers (issued as “1135 waivers” under the Social Security Act)...
Nursing Board License Actions – OIG & Medi-Cal Exclusions
December 7, 2020
Nurses and other health care providers must meet certain ethical standards in order to maintain their licenses. For example, in California, Welfare and Institutions Code §14043.6 and 14123, mandate that the Department of Health Care Services (DHCS) suspend a Medi-Cal...
Exclusion Screening & the Affordable Care Act
November 30, 2020
If the Affordable Care Act (ACA) is repealed – the potential effect on program integrity protections remains unclear. Over the last few years, the effect of an ACA repeal on health care and health plan coverage has been a topic...
