The Texas Office of the Inspector General for the state’s Health and Human Services agency recently published a reminder about the significance of exclusion screening. Texas, like many states, maintains a state exclusi...
DOJ False Claims Highlights in 2021 and What to Expect Ahead
Over the past 5 years, there has been a decreased in false claims recoveries by the DOJ. That trend was resoundingly reversed in fiscal year 2021. In a press announcement on February 1, 2022, the DOJ released the foll...
Screening Volunteers Against Exclusion Lists – Things to Consider
Background In 2013, the OIG issued an updated revised bulletin regarding the effect of exclusion from participation in federal programs. As part of that bulletin, the OIG addressed a number of somewhat gray areas incl...
The Role of Delegated Entities in Exclusion Screening
Under federal law, Medicare Advantage plans and Part D plan sponsors may delegate administrative or healthcare service functions to third parties, such as a medical group, pharmacy benefit manager, claims administration ...
Employers – Dig Deeper! The Role of Abuse Registries in Employee Screening
There are specific screening requirements for health care employers who receive federal funds as participants in federally-funded health care programs, but screening against abuse registries is an often-overlooked resour...
Exclusions Due to Overpayments – Cautionary Tales
While it seems unlikely that an organization’s mail management can result in exclusion from a federally funded program, many errors seem to be causing major headaches for well-intentioned, high- performing organization...
Vendor Management is a Risky Business
Screening employees and potential hires against federal and state exclusion lists can be relatively straightforward if an organization’s HR department maintains current employee data and utilizes the services offered b...
The Impact of FCRA and FACTA on Exclusion Screening
Background The Fair Credit Reporting Act (FCRA) was signed into law by President Nixon in 1970 and took effect April 25, 1971. The original purpose of the FCRA was to give consumers certain rights and protections rela...
CORPORATE INTEGRITY AGREEMENTS – AN OFFRAMP ON THE ROAD TO EXCLUSION
When a health care entity is faced with permissive exclusion from participation in federal health care programs, the Health and Human Services Office of Inspector General (OIG) has the discretion to offer a Corporate Int...