Maybe all of the above.
Although all state OIGs have an equal mandate to discover and prosecute medical facilities who have employed or partnered with excluded individuals or entities, Texas seems to take the cake when it comes to slamming facilities for exclusion screening lapses. Consider the following:
- More than 10% of last year’s exclusion-related fines were issued from the Texas OIG.
- Of the $529,390.94 in fines that were issued as a result of employment of excluded individuals since last April, $341,512.62 was from the Texas OIG.
- Over the course of 2014, Texas collected $1,098,350 in fines from medical facilities that were caught with excluded individuals on their employee or vendor rosters; second only to California, and more than double New York, the next highest state on the list.
- Of the most recent 10 exclusion-related fines issued, 6 were the result of self-disclosure. Only 4 were the result of direct OIG inquiry; and of those, 2 came from the Texas OIG.
Coincidence? We think not. But whether the increase in fines comes as a result of hard-hitting policies or overly-ambitious bureaucrats, the bottom line is the same: Texas facilities, take heed.