“No payment will be made by any Federal health care program for any items or services furnished, ordered, or prescribed by an excluded individual or entity.”
-U.S. Department of Health & Human Services, OIG
Entities that receive Federal and State funds should, as recommended by OIG, screen the two Federal databases—LEIE and SAM—at least monthly to ensure that employees, contractors and vendors are not excluded from participating in Federal health care programs. Many states have their own databases to screen as well.
Of note, for 2015, more than 50 cases totaling over $6.5 million dollars have been settled. In addition, several more cases have been settled for “voluntary exclusion.” And its not just skilled nursing facilities.
The top five in the list are: Skilled Nursing Facilities; Home Health and Home Care Agencies; Dentists and Dental Groups; Physicians and Hospitals
Some of these cases came about from identification through a data analysis project initiated by the OIG’s Office of Evaluation and Inspections. While it is comforting to know that your data is being looked at, you want to make sure you are looking at it too (if not first!).
LW Consulting, Inc. has some options for you to do this. Outsource the task to us or sign up for our LWEnSCheck subscription service to verify your staff and other business relationships are not Medicare, state excluded, or sanctioned individuals and entities. You can perform individual verifications as well as batch lists. State-based exclusion lists are also available.
Many states are now requiring and best practices suggest that facilities recheck sanctions and exclusions on a monthly basis. It is encouraged that facilities perform checks on a regular basis, so that they are very quickly made aware of any potential exclusions, avoiding large repayments. We agree that facilities should run at least a monthly batch check on all of their staff, providers, and contractors. It takes no extra time to do it, costs very little, and tells you what you need to know, when you need to know it.
$125.00 per state sanctioned database (optional)