What is the OIG Exclusion list?
The OIG Exclusion List is a database of certain individuals and organisations which are not allowed to participate in the federal healthcare programs. These lists are usually updated on the second week of each month, but are required to be updated each month.
The Healthcare providers participating in the federal healthcare programs are therefore advised to keep a regular check on the Exclusions list to avoid penalties of non-compliance.
What is an OIG Exclusion?
An OIG Exclusion is basically a penalty which is imposed by the Office of Inspector General (OIG) on individuals or entities in the healthcare sector who have been convicted of specific crimes. This exclusion prohibits them from participating in any federal or state healthcare benefit programs, which means that they cannot work as a provider or be employed by someone who participates in federal healthcare programs. It is also mentioned that the federal healthcare programs will not cover any items or services provided by the excluded party.
The OIG Exclusion process is regulated by the rules derived from various sections of the act. Receiving a notice of intent to exclude (NOI) does not automatically lead to exclusion. The OIG will review all the relevant information provided by the recipient of the NOI before making a final decision.
There are two types of Exclusions, namely, Mandatory and Permissive.
- Mandatory Exclusions – Mandatory exclusion are automatic penalties imposed by the Office of Inspector General (OIG) and Medicaid based on specific legal requirements. These exclusions are enforced when individuals or entities are convicted of certain serious crimes. The minimum exclusion period for these offences is five years.
- Permissive Exclusions – Permissive exclusions are applied for misdemeanours or defaults on federal student loans and usually last between one and three years, however, they can extend up to five years as well. After the exclusion period, the individual or entity must seek reinstatement at both the federal and state levels.
OIG Check
The OIG Check, which is often referred as OIG Exclusion check or OIG list check, is a process used to verify whether an individual or entity is excluded from participating in federal healthcare programs or not. This check is conducted against the exclusion list maintained by the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS).
An OIG Check is performed by healthcare organisations and providers to check that they are not inadvertently engaging with individuals or entities that could jeopardize their compliance status or lead to legal consequences.
OIG Excluded?
“OIG Excluded” refers to individuals or entities that have been prohibited by the Office of Inspector General (OIG) from participating in federal healthcare programs. This exclusion is a penalty imposed due to certain legal or regulatory violations.
Being “OIG Excluded” is a significant compliance issue for healthcare providers and organizations, impacting their ability to operate within federal and state healthcare systems.
