The Office of Inspector General (OIG) for the United States Department of Health and Human Services (HHS) HHS OIG is the largest inspector general's office in the Federal Government, dedicated to combating fraud, waste, and abuse and to improving the efficiency of more than 300 HHS programs. Most of OIG's resources go to overseeing Medicare and Medicaid - programs that represent much of the federal budget and affect the most vulnerable U.S. citizens. OIG's oversight extends to programs under other HHS institutions, including the Centers for Disease Control and Prevention, National Institutes of Health, and the Food and Drug Administration.
List of Excluded Individuals/Entities (LEIE)
The OIG holds accountable and has the authority to exclude individuals and entities from federally funded health care programs who bill HHS programs but do not meet federal health program requirements or who violate federal laws. Exclusion by the OIG from one program means exclusion from all HHS programs. Reasons the OIG may exclude an individual or entity include a conviction for Medicare or Medicaid fraud. Those that are excluded can receive no payment from federal health care programs for any items or services they furnish, order, or prescribe. This includes those that provide health benefits funded directly or indirectly by the United States (other than the Federal Employees Health Benefits Plan).
The OIG's exclusion database, the List of Excluded Individuals/Entities (LEIE) is updated monthly and contains the current list of excluded individuals and entities. Health care organizations are required to check all new hires and contractors, as well as monitor regularly against the LEIE to assure there are no services or items provided by and/or reimbursed on behalf of an excluded individual or entity. Anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties (CMP).
Two Types of OIG Exclusions
There are two types of exclusions that will put an individual or entity on the exclusion list: Mandatory and Permissive. Mandatory is enforced by law and requires the OIG to exclude when an individual or entity is convicted for committing felony crimes-Medicare or Medicaid fraud, or other felony offenses related to state or federal health care programs; felony convictions related to controlled substances; or convictions for patient neglect or abuse. For permissive exclusions, the OIG has discretion on whether or not to exclude. The offenses prescribing permissive exclusions are on a misdemeanor level.
How to Protect Your Organization
Protecting your organization and the patients it serves requires a proactive approach. Implementing a thorough screening and continuous monitoring program using aggregated data from multiple primary sources will help you steer clear of those on the OIG Exclusion List or from those who are excluded and intentionally evade detection.
The OIG exclusion list is a vital source to check when screening and monitoring your provider population, but it does not provide enough information to have a complete picture of compliance. Using Verisys' data platform FACIS®, the most comprehensive data set in the industry, for screening and monitoring health care providers, provides that complete picture.
The Verisys team pulls data from more than 5,000 data sources, adding roughly 75,000 records to the FACIS database each month, including the OIG Exclusion List. With one login, an organization can automate continuous monitoring and set alerts to receive notice of adverse action affecting one of your providers. Taking extra measures to check thousands of additional data sources protects your organization from financial and reputational risk and increases patient safety.
