In October, the Department of Health and Human Services Office of Inspector General (OIG) reported on three cases where healthcare organizations employed excluded individuals. In all cases, the healthcare organizations knew or should have known that the individuals were excluded, and in all cases the healthcare organization self disclosed the conduct to the OIG.
Valley View Regional Hospital of Oklahoma agreed to pay $44,307 for allegedly violating the Civil Monetary Penalties Law for employing an excluded individual.
Conroe Healthcare of Florida agreed to pay $145,106 for allegedly violating the Civil Monetary Penalties Law for employing an excluded individual.
Memphis Pathology Laboratory d/b/a American Esoteric Laboratories in Tennessee agreed to pay $6,780 for allegedly violating the Civil Monetary Penalties Law for employing an excluded individual.
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In the aforementioned cases, improperly hiring a single individual cost these organizations thousands of dollars. Furthermore, it wrongfully placed patients under the care of individuals determined by the OIG as ineligible to participate in healthcare programs. The OIG continues to crack down on providers who are improperly hiring individuals without conducting screenings against the List of Excluded Individuals and Entities. The OIG’s continued enforcement of screening requirements highlight their position of protecting federal healthcare programs’ beneficiaries and ensuring that excluded individuals do not fraudulently participate during their period of exclusion.
Screening for program exclusions should be viewed by your organization, and especially by executive management, the compliance officer and the Board of Directors, as a necessary part of doing business in the healthcare industry. Individuals and businesses can be excluded for a number of reasons, i.e., offenses related to the delivery of care; patient abuse or neglect; fraud, theft and other financial misconduct; and felony convictions related to controlled substances. Therefore, to protect your business, and especially the welfare of your patients and employees, sanction screening is a necessary part of the business.