Operating a healthcare facility, large or small, carries many responsibilities. Your primary concern is providing exceptional patient care, but there are also many rules and regulations that must be adhered to beyond just patient care.
One important rule is OIG Screening. If you are involved with healthcare administration or HR, you have likely heard of this term before. But what is OIG Screening and how does it impact your organization? We will provide a basic understanding of both in the following sections.
What is an OIG Exclusion?
To understand the screening process, we first need to talk about the Office of Inspector General (OIG). The OIG is a federal government agency that acts as a watchdog for the Department of Health and Human Services. Their main job is to protect federal healthcare programs, like Medicare and Medicaid, from fraud, waste, and abuse.
When a healthcare worker, contractor, or business commits a serious offense—such as Medicare fraud, patient abuse, or losing their medical license—the OIG takes action. They place that person or company on a “blacklist.” In the healthcare world, this ban is known as an OIG Exclusion.
Once someone faces an OIG Exclusion, they are legally barred from participating in any federally funded healthcare program. This means that no federal healthcare money can be used to pay for their salary, services, or the items they prescribe.
What is Exclusion Screening?
To summarize, Exclusion Screening is an essential aspect of the employer’s responsibilities. Because the federal government prohibits anyone receiving federal healthcare funds from doing business with an excluded person, every provider has an obligation as an employer to conduct exclusion screenings of all employees, vendors, and contractors. The OIG’s official sanctions list is called the List of Excluded Individuals/Entities (LEIE), which is a Federal database that provides you with a mechanism for conducting Exclusion Screening.
In short, when you are conducting an OIG Screening, you are essentially conducting a specific type of background check to determine if an individual is in violation of federal law regarding healthcare exclusion. However, it is important to keep in mind that OIG Screening does not only apply to physicians and nurses. All individuals who work with or for your facility should be screened, including: Receptionists, Customers Services Reps, IT Vendors, Suppliers of Medical Products or Services, etc.
What is the Consequence of Not Conducting a Background Check on a Potential New Employee?
You may be asking yourself, “How bad can it really get if we don’t conduct a background check?” The answer is heavy fines.
If you hire a person who is excluded from OIG, and you submit a claim for payment from Medicare/Medicaid for services that they performed, you are committing a crime. Even if you had no idea that this person was excluded and you were given the bill directly by Medicare, you will still be liable for Civil Monetary Penalties (CMP) for each person that you employed while they were on the OIG Exclusions list. The penalty amounts can exceed thousands of dollars for each violation, and you will also have to pay back any money received from the excluded person.
How often should you screen?
One mistake that many healthcare companies make is waiting until someone is hired to perform an Exclusion Screening on that person. The OIG updates the Exclusion list every month with new names being added to it. So if you want to remain safe and in compliance with the law, you should conduct an OIG Screening every month of your entire employee and vendor list.
The bottom line.
OIG Screening is not just about avoiding fines; it’s also about protecting patients and keeping your practice’s integrity intact. By doing Exclusion Screening regularly, you can feel confident that only qualified and trustworthy people are coming into your office and treating your patients.
