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OIG Sanctions and Exclusions, and State Termination – What’s the Difference?

The differences between sanctions, exclusions, and termination are crucial for healthcare organizations to understand when hiring and retaining skilled professionals. Sanctions 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) or a State Medicaid program authority. A sanction from a healthcare disciplinary or licensing board can lead to significant consequences, the most severe of which is an exclusion. Exclusions An exclusion results from an extreme sanction issued by the Office of Inspector General (OIG). Exclusions areLearn MoreOIG Sanctions and Exclusions, and State Termination – What’s the Difference?

OIG Self-Disclosure Protocol

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

Exclusion Lists FAQs

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 Exclusion Lists. According to 42 CFR Part §455.436(b) — Federal database checks, State Medicaid agencies must: (b) 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 for AwardLearn MoreExclusion Lists FAQs

OIG Exclusions, SAM Exclusions, and State Exclusion Lists – What’s the Difference

You know it’s essential to screen new hires, current employees, and vendors against the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE), the General Services Administration (GSA) System for Award Management (SAM), and all available State Exclusion lists. But why all these databases, and what’s the difference? The LEIE is the list of individuals or entities that the Office of Inspector General (OIG) excludes from federally funded healthcare programs, including Medicaid, Children’s Health Insurance Program (CHIP), and Medicare programs. The General Services Administration (GSA) System for Award Management (SAM) is a list of individuals and entities suspended and debarred from obtaining newLearn MoreOIG Exclusions, SAM Exclusions, and State Exclusion Lists – What’s the Difference

State Exclusion List FAQs

Why do States have an Exclusion List? States are required to notify the Health and Human Services (HHS) Office of Inspector General (OIG) only 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 will not be posted on the LEIE. This is a problem because, without a separate State sanction or exclusion list, it is difficult to determine if an individual or entity has been excludedLearn MoreState Exclusion List FAQs

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