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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, Office of Inspector General
 

Are you doing business with providers, vendors, or employees who have been excluded from Medicare or other government program participation?

 LWEnSCheck Has Your Solution

LWEnSCheck allows you to verify that your staff and other business relationships are not Medicare or State Excluded or Sanctioned Individuals or Entities. Perform individual verifications as well as batch lists. State-based exclusion, lists also available.

Monthly Exclusion Checks

The federal and state excluded provider programs affect every organization that receives federal or state dollars, for medical and health services rendered, social service funds, and grant programs. Excluded individuals may include those who commit fraud or program abuse, who neglect to pay back certain federal student loans, or who commit other violations of federal and state law, and as a result are excluded from performing any work for federal or state programs.  Organizations are not permitted to hire those individuals to administer or provide services that are in any way reimbursed or paid for with those public dollars. 

Buy It Now
Purchase a subscription to LWEnSCheck online.

 

LWEnSCheck Client Agreement
Pricing and Subscription Information

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.

Annual subscription:

$375/year

$125 per state sanction database (optional)

What are the federal guidelines on penalties if we unknowingly hire an excluded individual?

The law provides for penalties of up to $10,000 for each item or service furnished. The law also provides for up to three times the amount claimed for each item or service. The rule of thumb is that the penalty should not be less than twice the approximated amount of damages and costs sustained by the government, including investigation costs, prosecution, and administrative case review.

It is therefore critical that all healthcare providers and organizations that contract with government organizations or who receive state or federal dollars, check all new-hires before employment. Organizations must also conduct periodic follow-up checks of all employees, contractors, and medical staff to ensure that no new exclusion activity is appearing for existing staff or vendors.

Is it difficult to do this checking on our own?  How often do we need to do it?

Monthly exclusion checks are becoming the norm and many State Medicaid Agencies have their own exclusion databases.  Organizations have discovered trying to check multiple Federal and state databases through manual web page searches is very time consuming and it does not provide a strong audit trail, which is required to demonstrate a good-faith compliance effort.

Depending on what state you are in, you may be required to check all employees, vendors, contractors, and referring providers at least monthly.  The average manual verification process takes 15-25 seconds for each employee and vendor-- quickly adding up to hours or days of wasted staff time every month.  This manual process requires that you review the same results month after month.  LWEnSCheck reduces this time to minutes per month

What documentation should we have in case of an audit?

An audit trail should provide written proof of all names searched, the date they were initially searched and every subsequent date thereafter, the date each database was updated, a list of all possible matches that were reviewed, and the results of that review and the determination made.

 


 
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