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Termination of Provider Participation FAQs

Section 6501 of the Affordable Care Act requires each State Medicaid program to terminate any provider who has been terminated under Medicare or by another State Medicaid program. The Centers for Medicare & Medicaid Services (CMS) has defined “termination” as occurring when a State Medicaid program, CHIP, or the Medicare program has taken action to revoke a Medicaid or CHIP provider’s or Medicare provider or supplier’s billing privileges and the provider, supplier, or eligible professional has exhausted all applicable appeal rights or the timeline for appeal has expired. The requirement to terminate only applies in cases where providers, suppliers, orLearn MoreTermination of Provider Participation FAQs

Exclusion, Sanction, and Termination, what’s the difference?

The differences between exclusion, sanction, and termination are crucial for healthcare employers to understand when seeking to find and retain skilled professionals. Because the HHS-OIG and GSA-SAM federal databases refer to exclusions as “sanctions,” healthcare and compliance professionals often confuse the two terms because they are incorrectly used interchangeably. A sanction results from an administrative hearing where an individual or entity violates an administrative rule, civil law, or criminal offense, leading to various penalties. Sanctions are enforced by the Office of the Inspector General (OIG) in the U.S. Department of Health and Human Services or a state Medicaid program. A sanction from aLearn MoreExclusion, Sanction, and Termination, what’s the difference?

Medicare Exclusion Lists Frequently Asked Questions

Q: Which exclusion list should I use to check employees and vendors, the OIG-LEIE or the GSA-SAM? It is recommended that you check both the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities (LEIE) and the General Services Administration’s (GSA) System for Award Management (SAM) databases as well as all of the publicly available State Medicaid Exclusion Lists. According to 42 CFR Part §455.436(b) — Federal database checks, State Medicaid agencies must: Check the Social Security Administration’s Death Master File, the National Plan and Provider Enumeration System (NPPES), the List of Excluded Individuals/Entities (LEIE), the System forLearn MoreMedicare Exclusion Lists Frequently Asked Questions

Suspension and Debarment Frequently Asked Questions

How is the DOI Debarment Program organized? The Department of the Interior (DOI) Office of Inspector General (OIG) Administrative Remedies Division (ARD) develops cases. It refers to administrative or non-administrative action recommendations from the Department of the Interior Strategic Data Office (DOI SDO). After the DOI SDO initiates proceedings, ARD staff serves as a case representative. The DOI SDO manages the suspension and debarment program, reviews ARD referrals, issues notices, presides over contested notice proceedings, and issues determinations. Suppose the SDO finds that there is a genuine dispute of material fact. In that case, it may refer the matter forLearn MoreSuspension and Debarment Frequently Asked Questions

The Difference Between the OIG-LEIE, GSA-SAM, and State Exclusion Lists

There are two federal exclusion lists: the Health and Human Services (HHS) Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE) and the General Services Administration (GSA) System for Award Management (SAM.gov) Exclusion list, plus 43 State Medicaid/Medicare exclusion lists, but how do they differ, and why do they exist? What is an exclusion, and how does it affect your organization? Exclusions are administrative actions taken against an individual or entity by HHS OIG, a state agency or Medicaid Fraud Control Unit (MFCU), or one of the many agencies associated with SAM.gov. Exclusions are levied against employees, vendors, suppliers,Learn MoreThe Difference Between the OIG-LEIE, GSA-SAM, and State Exclusion Lists

Why States Maintain Separate Medicaid Exclusion Lists

States must only notify the Health and Human Services (HHS) Office of Inspector General (OIG) when they exclude or terminate an individual or entity based on Federal law. States are not required to notify the OIG (nor should they) of actions based on State laws because if the sanction fails to meet the criteria for a federal exclusion, the exclusion would not be posted on the LEIE. Without a separate State sanction list, providers could not determine whether a person or entity had been excluded or terminated. Also, even if the OIG disagrees with a State action based on federal grounds,Learn MoreWhy States Maintain Separate Medicaid Exclusion Lists

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