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Category: OIG

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

By support@poweredbygnosis.com

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?

OIG Self-Disclosure Protocol

By support@poweredbygnosis.com

Why Self-Disclosure Is Important The OIG has long emphasized the importance of dealing with Federal healthcare programs with integrity. All healthcare industry members have a legal and ethical duty to do so. This duty includes an obligation to detect and prevent fraudulent and abusive activities, including implementing specific procedures and mechanisms to investigate and resolve instances of potential fraud involving the Federal health care programs. Whether as a result of voluntary self-assessment or in response to external forces, participants in the healthcare industry must be prepared to investigate such instances, assess the potential losses suffered by the Federal healthcare programs,Learn MoreOIG Self-Disclosure Protocol

Medicare Exclusion Lists Frequently Asked Questions

By support@poweredbygnosis.com

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

By support@poweredbygnosis.com

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

By support@poweredbygnosis.com

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

By support@poweredbygnosis.com

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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