Global warming and the Artic freeze are not our forte, but we’ve granted ourselves the liberty of forecasting what our ‘weathermen’ see coming up on the horizon: The Great Exclusion Snowball.

Over two months ago, we blogged about the the OIG alert targeting small-time medical practices.  Last week, Greenberg Traurig LLP reported on Lexology that the OIG introduced a new task force, consisting of 10 attorneys focused on issuing CMPs (civil monetary penalties) and exclusions to physicians convicted of overbilling and kickbacks.  In practical terms, we’ve seen the numbers of excluded individuals climbing exponentially from year to year – along with the number and dollar amount of fines issued as a result of employing them.

All of which leads us to believe that we are standing at the cusp of The Great Exclusion Snowball.

It is so easy for the OIG to exclude a provider from doing business with Medicaid and Medicare.  It’s a penalty that is simple to enforce, and perceived as fair in the public eye.  And that is why it is a punishment that will likely only continue to increase in popularity as time goes on.

So keep your scarf on.  Looks like we’re in for some nasty weather.