Your Anesthesia Compliance Tip for today is on the
First we must focus on Mandatory exclusions:
These are exclusion by which the OIG is required by law to exclude from participation in all Federal health care programs individuals convicted of the following types of criminal offenses:
- Medicare or Medicaid fraud, or any offenses related to the delivery of services under Medicare, Medicaid, or State programs;
- patient abuse or neglect;
- felony convictions for health care-related fraud, theft, or other financial misconduct; and
- felony convictions relating to unlawful manufacture, distribution, prescription, or dispensing of controlled substances.
Secondly there are Permissive exclusions:
In which the OIG has discretion to exclude individuals and entities on a number of grounds,
- including misdemeanor convictions related to health care fraud other than Medicare or a State health program,
- fraud in a program funded by any Federal, State or local government agency;
- misdemeanor convictions relating to the unlawful manufacture, distribution, prescription, or dispensing of controlled substances;
- suspension, revocation, or surrender of a license to provide health care for reasons bearing on professional competence, professional performance, or financial integrity;
- provision of unnecessary or substandard services;
- submission of false or fraudulent claims to a Federal health care program;
- engaging in unlawful kickback arrangements;
- defaulting on health education loan or scholarship obligations; and controlling a sanctioned entity as an owner, officer, or managing employee.
To avoid Civil Monetary Penalty liability, health care entities need to routinely check the (LEIE) List of Excluded Individuals and Entities to ensure that new hires and current employees are not on the excluded list.