Is your organization conducting exclusion checks to support your compliance program?
Running monthly exclusion checks helps your organization support your compliance program by ensuring your organization is not employing excluded individuals or partnering with vendors or businesses that are excluded. Not conducting exclusion checks puts your organization at risk of fines and sanction from participating in State and Federal programs. If you are unsure about who has to comply or the background of this mandate, you can read more about that here.
An exclusion does not immediately appear on a list. It can take an average of 173 days for an exclusion to appear on the Office of Inspector General (OIG) LEIE) and up to two years for an exclusion to appear on a state list. There are also two types of exclusions – mandatory and permissive. Mandatory is exactly as it is defined. It is mandatory that the individual or business be excluded from all Federal Healthcare programs. Permissive exclusions can be optionally applied based upon the offenses but could still result in an individual or business being excluded.
If your organization is conducting exclusion checks, are you complying with your State requirements by searching the State Medicaid exclusion sources?
It is just as important comply with your State requirements and search Medicaid excluded lists. By running exclusions against the State Medicaid lists, you are ensuring that you are not employing an individual or partnering with vendors or businesses that have been excluded within your state or surrounding states. In Pennsylvania, the Medicheck list identifies these providers, individuals, and other entities who are unable to participate in the Medical Assistance (MA) Program. If you are not in the state of Pennsylvania, you will want to check into your local exclusions list.
How can we help?
LW Consulting, Inc. (LWCI) offers a cost-effective exclusions software, LWEnSCheck® Exclusions Software, as a monthly licensing subscription to entities to utilize in completing their monthly exclusions. LWCI exclusion consultants can set your team up to conduct monthly exclusions in our proprietary software and train your team on downloading the monthly reports for compliance retention. If your team has been struggling to keep up with monthly exclusions, outsource your work to our exclusion consultants. Our consultants conduct monthly exclusion services for health systems, health plans, and small providers.
LW Consulting, Inc. (LWCI) offers a comprehensive range of services that can assist your organization in maintaining compliance, identifying trends, providing education and training, or conducting documentation and coding audits. For more information, contact Ashley Popovich at [email protected] or call (570) 431-0100. We would be happy to talk through your exclusions process and how LWEnSCheck® can help!
| Sources: |
| HHS-OIG. (n.d.). Exclusions | Office of Inspector General | U.S. Department of Health and Human Services. https://oig.hhs.gov/exclusions/ |
| MediCheck List | Department of Human Services | Commonwealth of Pennsylvania. (n.d.). https://www.pa.gov/en/agencies/dhs/report-fraud/medicheck-list.html |
