By this time, most CHCs have a compliance plan. Maybe it’s not the plan you dreamt of when you started but you have something in place nonetheless. One aspect of an “effective” compliance plan that does not receive perhaps enough attention is evaluating ALL staff (and board members) to see is anyone is on the OIG Exclusion list. You are looking for anyone legally affiliated with your CHC to see if they are listed.
They may be listed due to a personal exclusion, affiliation/employment with an excluded institution, or even be a clinician who defaulted on federal student loans. Simply stated, you never know who might be on the list or why. BUT, in the end, you cannot engage with someone who is on the exclusion list.
A quick search of the OIG Exclusion’s web site (http://exclusions.oig.hhs.gov/) will provide you with a wealth of info such as OIG History, how to report fraud/abuse, whistle blower rights, safe-harbor regulations, self-disclosure processes… and the list goes on.
The following Quick Tips are helpful in terms of what the site can do and recommendations depending on the size of your search:
- Because the databases include only the name known to the OIG at the time the individual was excluded, any former names used by the individual (e.g., maiden name, previous married name, etc) should be searched in addition to the individual’s current name.
- An individual with a hyphenated name should be checked under each of the last names in the hyphenated name (e.g., Jane Smith-Jones should be checked under Jane Smith and Jane Jones, in addition to Jane Smith-Jones).
- When you check the LEIE, using the Online Searchable Database or the Downloadable Data file, you should maintain documentation of the initial name search performed and any additional searches conducted in order to verify results of potential name matches.
- If you are checking only a few names, choose the Online Searchable Database. You can search up to five names at once.
- If you are checking many names, consider downloading the Downloadable Data File into your computer’s spreadsheet or database program. This will enable you to use that program’s search functions to crosscheck your names against the thousands of names on the LEIE.
- Be sure to double-check that you have the correct spelling of any names before starting your search.
- In order to achieve the most accurate search results, enter only the first few letters of the name.
- Do not forget to take the final step of identity verification using the Social Security Number (SSN) for an individual or Employer Identification Number (EIN) for an entity. It is not sufficient to simply find a matching first and last name on the LEIE.
- If you find a potential match using the Downloadable Data file, you must still verify the results by entering the SSN for an individual or EIN for an entity on the Online Searchable Database. (Note: The Privacy Act prohibits the distribution of SSNs so they cannot be included in the Downloadable Data file).
- If a search result does not contain a DOB, UPIN, NPI, EIN, or SSN, it is not available from the OIG. Contact the Exclusions Staff to determine if there is any other information available.
There is not time like the present to start this process. It’s important and should be standard operating procedure to protect your CHC from engaging with staff who may put you and your team at risk.