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Highlights from ProviderTrust: OIG Special Advisory Bulletin Provides Guidance on Required Health Care Provider OIG Exclusion List Searches for Individuals and Entities
Date:5/9/2013

Washington, DC (PRWEB) May 09, 2013

Highlights from the Special Advisory Bulletin include:

1. The Special Advisory Bulletin indicates that providers should check the OIG List of Excluded Individuals and Entities (LEIE) upon hire and periodically for employees and contractors. The OIG notes that there is no statutory requirement to search the LEIE exclusion list, but that the OIG updates the LEIE exclusion list monthly "so screening employees and contractors each month best minimizes potential overpayment and Civil and Monetary Fines".

2. The Advisory recommends that Providers review job descriptions, categories of care, and contractual relationships to determine whether an item or service being provided is "directly or indirectly, in whole or in part, payable by a Federal health care program. If the answer is yes, the best mechanism for limiting CMP liability is to screen all persons that perform under that contract or that are in that job category".

3. The Special Advisory Bulletin explains that no Federal health care program payment can be made for items or services beyond patient care, and includes those for administrative, transportation, filling prescriptions, inputting prescription information, preparation of surgical trays or reviewing treatment plans, regardless of whether such services are separately billed or are included in bundled payment.

4. The Special Advisory Bulletin explains that the prohibition for payment applies to administrators such as executives, human resources, information technology, accounting, general counsel and office managers who are on the OIG exclusion list.

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