Just the other day, a routine search of a client’s employee listings turned up a potential match on the Texas OIG site. As a pre-‘90s listing, there was no way to verify the social the way that I usually would, but I did notice a small web comment next to the listing that said ‘Deceased’. Hm. Seemed like pretty concrete evidence that the (still very much alive) employee in question was not the same party. But since I’d never seen a web comment like that on an OIG site, I called the Texas OIG directly, just to be sure.
“I noticed a notation next to the listing that says ‘Deceased’,” I told the nice lady who answered the call. “Does that mean that the excluded person already died?”
“Yes,” she confirmed. “It’s rare that we’ll actually get that information, but when we do, we post a comment like that.”
“But if you know that the person has already died, why don’t you just take him off the list?!” I asked incredulously.
“Well, nobody gets taken off the list unless they are reinstated,” she answered simply.
So, there you have it folks – a new/old piece of information for those of us in the field who thought we’d seen it all.
Bottom line: There is absolutely NO way off an exclusion list except reinstatement. Even if an excluded individual has already completed his/her term of exclusion…even if s/he has cleared his/her name of all related allegations…even if s/he has already DIED—s/he will not be taken off the list unless the entire reinstatement process is completed! Let the employer beware…
For the Federal OIG’s recent article on reinstatement, check out https://oig.hhs.gov/exclusions/reinstatement.asp.