OIG Exclusions: To disclose, or not to disclose…that is the question.

Posted by Frank Strafford on October 23, 2014 in OIG Penalties,

OIG ExclusionsYou’ve discovered an OIG exclusion blooper.  Now what?

If you’re like most administrators, you’d probably opt to fire the excluded employee, bury the evidence, and hope that the OIG never finds out about it.  After all, who in their right mind would actively call the OIG’s attention to a mistake like that?!

Anyone who wants to prevent a worse mistake.  That’s who.

Under the OIG’s self-disclosure clause, contractors are required by law to self-disclose upon discovering an excluded individual within their employee ranks.  Failure to self-disclose can result in contractor suspension or debarment.  Not something you’d want to play around with.

On the face of it, self-disclosure is scary.  It means shoving your failures directly under the nose of the OIG, and inviting whatever repercussions may come about as a result.

On the other hand, from a damage-control perspective, self-disclosure is the wisest course of action to take.  It may result in fees and fines; but it will also protect your company or organization from full-scale suspension, not to mention the whopping fees that are sure to be slapped onto a facility perceived as willfully flouting the law.  Self-disclosure gives you the chance to explain and defend yourself before you’ve been accused.

A confession in time indicates your contrition and willingness to cooperate with the authorities.  And in return, the authorities will be that much more likely to cooperate with you.

For instructions on submitting a Self Disclosure Form, see https://oig.hhs.gov/compliance/self-disclosure-info/files/Contractor_Self-Disclosure_Guidance_April_2014.pdf.  

Please refer to this resource for more helpful information on OIG Exclusions and LEIE searches.

 

 

 

 

 

About Frank Strafford

About Frank Strafford

Related Articles

How to Protect Yourself From Third ...

May 29, 2015

Healthcare companies can have a strong exclusion screening program and have it strictly implemented by their Human Resources and Compliance Departments. However, the problem can very well lie with thi...

The Role of OFAC in U....

March 16, 2022

The recent events in Ukraine have resulted in an unprecedented imposition of crippling financial sanctions against Russia by the United States, the European Union and multiple countries around the glo...

Some Medicaid Plans May Overstate Provider ...

October 28, 2022

Medicaid patient access to care has been a challenge for years. Many providers have historically opted to not participate in Medicaid because of the low reimbursement rates and the increased administr...

Understanding OIG Exclusions

OIG Exclusions Screening Process

Exclusion FAQS

Quick OIG Exclusion Basics

Employing Excluded Individuals

Consequences to Employing an Excluded Individual

OIG Compliance Law

Laws and Publications on OIG Compliance

More Compliance Resources

Our Culture

We build the best, so you can perform at your best.

Trusted for Good Reason

  • ✓ Guaranteed accurate
  • ✓ Certified Secure
  • ✓ Audit Proof
  • ✓ Feature-rich reporting
  • ✓ Round the clock real-time-data
  • ✓ Processing fully automated

Security First

  • ✓ Cloud hosted
  • ✓ Encrypted data
  • ✓ Real-time backups

Trusted for Accuracy

  • ✓ Physical security
  • ✓ Restricted access
  • ✓ Single sign-on
  • ✓ Password security
  • ✓ Certified secure
  • ✓ Cross checking

HEALTHCARE ESTABLISHMENTS NATIONWIDE COUNT ON STREAMLINE VERIFY

5

60%

Average workload reduction by implementing the Streamline Verify program

5

10K

Establishments trust Streamline Verify nationwide

5

2011

Serving the healthcare industry’s unique compliance needs since 2011

5

24X

Setting standards with hourly synchronization to primary source data