Home Health & Hospice Week

Slacking off on checking the HHS Office of Inspector General's exclusions list can cost you big.

The OIG keeps a database of providers who have been excluded from participating in Medicare, Medicaid and other federal health care programs, and you should check it whenever hiring a new person, says attorney Linda Baumann with Reed Smith in Washington. You should also routinely check the list throughout the year because the OIG updates it frequently.

When someone is "excluded," it means that absolutely no federal health care dollars can be paid for items or services the person (1) furnishes or (2) prescribes or directs, the OIG makes clear in a Special Advisory Bulletin on the matter. "This payment ban applies to all methods of Federal program reimbursement, whether payment results from itemized claims, cost reports, fee schedules or a prospective payment system (PPS)."

If you hire an excluded individual, you could find yourself in big trouble. In fact, you could wind up excluded yourself. Even if you don't get excluded, you could pay whopping fines - up to $10,000 for each item or service furnished while the person was excluded.

"I've been working with a number of clients lately who have been investigated because the government has determined that they billed federal health care programs improperly for services provided by an excluded individual," Baumann reports. 

Editor's Note: For more information on exclusions, including the Special Advisory Bulletin and the list itself, go to http://oig.hhs.gov/fraud/exclusions.html.