Matching your employees against these lists is a Federal and State mandate. In fact, every healthcare provider in the country is required to do it. Recently, in a letter to State Medicaid Directors, Herb B. Kuhn, Deputy Administrator and Acting Director for the Center for Medicaid and State Operations stated, "States should require providers to search the HHS-OIG website monthly to capture exclusions and reinstatements that have occurred since the last search."
Bases for exclusion can include convictions for program-related fraud and patient abuse, licensing board actions, license revocation / suspension / surrender and default on Health Education Assistance Loans.
Currently, the Office of the Inspector General of the U.S. Department of Human Services (OIG) and the New York State Office of the Medicaid Inspector General (OMIG) maintain over 50,000 records combined for excluded providers, and the numbers are growing every day.
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Penalties can be applied if a provider knowingly employs or contracts with an excluded individual or entity to provide services or items for which payment is sought under any federal health care program. These penalties include civil monetary penalties of up to $10,000 per service, an assessment of up to three times the amounts paid for the services, and even exclusion from the federal health care programs.