Understanding the OIG’s List of Excluded Individuals/Entities

Posted by Frank Strafford on October 27, 2014 in EPLS, Exclusion Screening, Exclusions, GSA, Healthcare HR,

Understanding the OIG’s List of Excluded Individuals/EntitiesIn order to protect Federal healthcare systems from unscrupulous employees and contractors, the Office of the Inspector General regularly updates a List of Excluded Individuals/Entities (LEIE) to help human resources departments streamline OIG screening processes.

Federal health programs, including but not limited to Medicare and Medicaid, will not pay for services or products provided by OIG excluded individuals. They may also cut off funding to organizations that employ or contract individuals on the OIG exclusion list.

So how does someone end up on this list, and can they get off it once they’ve been excluded?

Mandatory Exclusions
There are several instances in which the OIG is required to exclude an individual. These include convictions for crimes related to a healthcare program or to patient abuse and neglect. An individual must also be excluded if they are convicted of a felony related to health care fraud or misuse of a controlled substance. Any one of these exclusions comes with a minimum of five years on the OIG exclusion list. Two will result in a minimum of 10 years, and three or more results in permanent exclusion.

Permissive Exclusions
Permissive inclusions are more flexible, and are generally issued at the judgement of the OIG. A misdemeanor conviction of healthcare fraud, or general fraud, can result in an exclusion term of three years or more. Misdemeanors convictions granted for obstruction of an investigation or controlled substance abuse can also result in three years or more on the list. License revocation or suspension, kickbacks, and various other offenses associated with job performance and prohibited activities will land individuals on the exclusion list for more flexible terms.

Can OIG Excluded Individuals get Off the List?
An individual has to apply for reinstatement to be removed from the OIG exclusion list, regardless of the term of their exclusion. Unfortunately, applying for reinstatement through the OIG will not result in reinstatement through other excluding bodies. The process for OIG excluded individuals to get off the OIG list is complex, so it’s best to avoid ending up there at all.

About Frank Strafford

About Frank Strafford

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