Employee Exclusion List Screening

As discussed at the HCRMS regional seminars, it is critical that facilities perform an OIG (Office of the Inspector General) exclusion list screen on all prospective employees and current employees should be screened on a scheduled basis. The attached excerpt was taken from the Title 42-The Public Health and Welfare, Chapter 7-Social Security, Subchapter XI-General Provisions, Peer Review, and Administrative Simplification- Part A – General Provisions (Excerpt 1320a-7) and outlines very clearly what constitutes an exclusionary offense. Over the past several months HCRMS has had several facilities that have identified current employees on the OIG exclusion list. What does this mean to them and possibly to you? Simply put, if your facility employs an individual who has been excluded from the Medicare and Medicaid program for any of the reason listed on the attached excerpt, Medicare and Medicaid can deny payment for any services rendered during the excluded employee’s tenure. That is correct, any and all payment for services provided to Medicare/Medicaid recipients may be denied and the facility has no recourse. HCRMS recommends that the OIG exclusion list be checked for every new employee prior to hire and that a system be established to ensure that current employees are screened on a regular basis. If you should have any questions regarding protocols or recommendations please feel free to discuss with your risk manager or call 734-996-2700. For further information regarding the OIG Exclusion list please access the OIG governmental website.

OIG Exclusion Information