When the Federal OIG threatens to enforce exclusion, they mean business.  Pronto.

The Federal OIG’s Ohio State Medicaid Fraud Control Unit: 2014 Onsite Review slaps the Ohio State Unit on the grounds that it ‘did not consistently submit reports of convictions within the appropriate timeframe to OIG for the purpose of program exclusion’.

According to the 2012 revised Performance Standard 8(f), the Unit has a responsibility to transmit “all pertinent information on MFCU convictions within 30 days of sentencing, including charging documents, plea agreements, and sentencing orders.”

The OIG’s recently-published in-depth report states:

Of the 403 reports of convictions that should have been sent to OIG for exclusion, the Unit reported 320 convictions within the appropriate timeframe. Eighty-three convictions were reported more than 45 days after sentencing. Fifty-two of these eighty-three convictions were submitted to OIG after the beginning of our review and more than 160 days after sentencing, with 13 of these submitted more than 1,000 days after sentencing. During onsite discussions, the Unit stated that it was revising its policies and procedures for reporting convictions to OIG.

No exceptions, no excuses – not even for the Ohio State Medicaid Fraud Control Unit.