THE ULTIMATE GUIDE TO EXCLUSIONS. Everything You Need to Know About Exclusion Monitoring

Transcription

1 THE ULTIMATE GUIDE TO EXCLUSIONS Everything You Need to Know About Exclusion Monitoring

2 Content Introduction Background of the OIG Definition of an Exclusion Fines & Penalties Differences Between the Exclusion Databases Industry Best Practices Additional Resources The contents of this document should not be construed as offering or providing legal advice. The material is a compilation of public record research and the interpretation of ProviderTrust. You should consult with your own legal counsel as ProviderTrust is not a law firm.

3 Introduction Welcome! You re in good hands. At ProviderTrust, we understand the complexities of healthcare compliance and, while a critical part of care, just how burdensome it can be on our readers. We believe simplifying healthcare compliance helps you perform your job better, and helping you is what matters most to us! We not only offer software solutions to resolve your compliance needs, but we also aim to provide you with resources that help you more easily digest the complex ins-and-outs of compliance and federal regulations. This ebook will help you understand the details of the exclusion monitoring process, as well as educate you on the risks of not complying. Our hope is that by reading this ebook you will feel more confident in tackling your compliance goals. We ve also included a list of additional resources to guide you through the process. Read on to learn more, and please reach out with any additional questions you may have; we are happy to help in any way that we can! The Ultimate Guide to Exclusions 3

4 Introduction About the Author Michael Rosen, Esq., a ProviderTrust co-founder and Tennessee native, brings more than 20 years of experience founding and leading service-oriented businesses. A graduate from the University of Texas and, later, the University of Memphis Law School, Michael has received numerous accolades such as Inc Magazine s Inc 500 Award, Nashville Chamber of Commerce Small Business of the Year and Music City Future 50 Award. He brings a deep understanding of the risk mitigation industry and enjoys providing solutions for organizations as they manage their people and resources. What I love about working in the risk mitigation arena is that you can develop innovative tools that tackle real world problems by listening to people and crafting solutions that actually make their lives better. Before co-founding ProviderTrust, Michael co-founded Background America, Inc., which was acquired by Kroll Inc. and then Marsh & McLennan Co: NYSE: MMC. During his 15-year tenure, he became President of the background screening division which employed 1,000 people in 7 countries. In addition to developing their background screening strategy and expanding it globally, he launched industry-leading identity theft and restoration service lines. Connect with Michael: LinkedIn ProviderTrust Blog The Ultimate Guide to Exclusions 4

5 Introduction Industry Insights Compliance: What s all the fuss about? Compliance impacts every industry across the globe. It was set in place to bring order and safety to the work force. Specifically, healthcare compliance has made significant advances in improving healthcare, including cracking down on fraud and abuse. Healthcare spending is one of the biggest budget items in the United States each year. With approximately 20 million people working in healthcare providing services, unfortunately, fraud and abuse in healthcare reaches billions per year. In the beginning stages of 2011 (ACA), enforcement placed a major focus on pre-hire eligibility. Now, with billions of dollars in fraud occurring, enforcement has begun placing a larger focus on monitoring employees beyond the initial hire. This effort addresses a gap in communication, where employees could get hired before a previous fraud has been reported. Compliance is the art of governing within a set of rules and practices in order to create a culture of meeting and exceeding regulations, rules, and requirements. - Michael Rosen Why is it so important? Although healthcare compliance has come a long way, there is still a long journey ahead. The current system, based largely off a pay and chase approach, offers very few safeguards. For example, the process to receive Medicare and Medicaid payments requires little approval, making it easy to game the system. It s a complicated system in which chances of getting caught are small - this creates an environment where fraud can run rampant. The good news is that for every $1 spent on fraud enforcement, there is a return of $8 to the U.S. Treasury. That s a great ratio! On top of that, many old and new laws exist to support efforts that specifically address healthcare fraud including: Federal Health Care Fraud and Abuse Laws The False Claims Act (31 U.S.C ) The Anti-Kickback Statute (42 U.S.C 1320a - 7b(b) Safe Harbor Regulations (42 C.F.R The Ultimate Guide to Exclusions 5

6 Background of the OIG What is the purpose of the OIG? Do you ever wonder what life would be like without an enforcement cop or policy maker in healthcare? It s hard to imagine, even if you subscribe to the idea that government oversight is too onerous and creates more harm than good. The Office of Inspector General (OIG) is a system of safeguards in healthcare for Health and Human Services (HHS). In it s most basic sense, it s a governing agent that finds, eliminates and punishes fraud and abuse violators. The Ultimate Guide to Exclusions 6

7 Background of the OIG The OIG Mission The mission of the OIG, as stated on their website: To protect the integrity of Department of Health and Human Services (HHS) programs as well as the health and welfare of program beneficiaries. For more information on the OIG, visit: oig.hhs.gov You may also subscribe to our blog for on-going training and updates! Visit oig.hhs.gov The OIG acts in the people s best interest by regulating and enforcing violations of healthcare fraud, waste and abuse. Created in 1976, the OIG oversees more than 300 other HHS programs. The most common are Medicare, Medicaid, TriCare and Children s Health Insurance Program (CHIPs). Others include the Centers for Disease Control and Prevention, National Institutes of Health and the Food and Drug Administration. The OIG for HHS is the largest Inspector General s office in the Federal Government, with approximately 1,600 employees. Subscribe to our Blog The Ultimate Guide to Exclusions 7

8 Background of the OIG Who Does the OIG Govern? There are 11 departments in the OIG infrastructure: they revolve around auditing, investigating, enforcement, evaluating and policy making. In this section we will address the enforcement function of the OIG. The three OIG departments that focus on the enforcement of healthcare fraud: Office of Investigations (OI) Conducts criminal, civil and administrative investigations of fraud and misconduct related to HHS programs, operations and beneficiaries. Office of Audit Services (OAS) Conducts independent audits of HHS programs, grantees and contractors to examine the performance of HHS programs and responsibilities, as well as provide assessments. Office of Evaluation and Inspections (OEI) Conducts national evaluations of HHS programs and issue recommendations focused on preventing fraud, waste and abuse. The current Inspector General for HHS is Daniel R. Levinson. Each year, typically in the spring, the OIG releases its annual Work Plan that outlines the areas of focus and enforcement by the office and its strategic plan for the year. The Ultimate Guide to Exclusions 8

9 Background of the OIG OIG Enforcement Success Convictions related to fraud consistently represented the majority of criminal convictions over the past five years, according to the OIG Report on 2014 Medicaid Fraud Control Unit performance (MFCU). About three quarters of the criminal convictions from the MFCU involved healthcare fraud and abuse. MFCU, along with the other branches of the OIG, play an important role in ferreting out, deterring and prosecuting healthcare fraud and abuse. According to the OIG Semiannual Report for 2015: Through its enforcement efforts in the first half of the fiscal year 2015, the OIG has already recovered $1.8 billion in total investigative and audit receivables. The OIG reported 486 criminal cases against individuals and companies that engaged in crimes against HHS programs. 1,735 individuals and entities are excluded from participation in federal healthcare programs. For more information on the OIG and their role in compliance, visit them online. Visit oig.hhs.gov Subscribe to our Blog In the Fiscal Year 2013 the OIG: Was responsible for overseeing $0.26 of every federal dollar spent 84% percent of its efforts were dedicated to oversight of Medicare and Medicaid Recovered $5.8B in total investigative and audit receivables The return on investment (ROI) was $8 to $1 spent in enforcement efforts Summary The OIG ensures federal healthcare dollars are used wisely, legally and in conformance with regulations. Violators who do not properly bill for government funding are prosecuted with fines and penalties, including exclusion from participation in federal healthcare programs. Without the tireless efforts of the dedicated OIG enforcement staff, there would be billions of dollars of fraud, waste and abuse. The Ultimate Guide to Exclusions 9

10 Definition of an Exclusion What is an exclusion? It sounds like a simple question with a simple answer, yet in a lot of cases, there is quite a bit of confusion around the true definition of an exclusion, especially the difference between an exclusion and a sanction. By definition, an exclusion is an administrative action taken against an individual or entity (aka vendor) by the Department of Health and Human Services, Office of Inspector General (OIG). A sanction, on the other hand, is typically an early indicator of a potential exclusion. There is confusion in the marketplace because the OIG and SAM federal data sets refer to an exclusion as a sanction. For purposes of this ebook, a sanction means a disciplinary action taken against a person s license by a state professional license board. This chapter further breaks down the basics of exclusions, how they originate and the repercussions of receiving an exclusion. The Ultimate Guide to Exclusions 10

11 Definition of an Exclusion Exclusion Details So what does it mean to have an excluded employee? The American Health Lawyers Association (AHLA) researched the latest Special Advisory from the OIG and provided some helpful insight: NOTE The term person referes to any individual or entity. The effect of an OIG exclusion is that no federal healthcare program payment may be made for any items or services furnished: 1) by an excluded person; or 2) at the medical direction or on the prescription of an excluded person. This payment prohibition applies to all methods of federal healthcare program payment, whether from itemized claims, cost reports, fee schedules, capitated payments, a prospective payments system or other bundled payment, or other payment system and applies even if the payment is made to a state agency or a person that is not excluded. Basically, no program (Medicare and Medicaid) payment will be made for any items furnished or services performed by excluded individuals and entities. This not only applies to those actually licensed and working with patients; as the OIG website states, this ruling also extends to those indirectly involved as well (yes, this means everyone from cooks and janitors to those in HR and financial positions). As you look to monitor employees, keep in mind the importance of monitoring all of your employees. The Ultimate Guide to Exclusions 11

12 Definition of an Exclusion Enforcement The OIG has the authority to enforce exclusions against individuals or entities. They mandate that healthcare organizations not hire or do business with excluded or sanctioned individuals or entities. If an individual or entity is excluded, he/she/it is prohibited from participating in reimbursements for, or from, federally funded healthcare programs - CMS, Medicare and Medicaid. Once an individual or entity is excluded, he/she/it is considered excluded in all states. In other words, under the Affordable Care Act, an individual or entity excluded in one state is not permitted to participate in federal healthcare funds in all other states. A person or entity can be excluded by a federal agency, the OIG, or by a state Medicaid agency. Types of Exclusions Mandatory vs. Permissive Mandatory Exclusion: Felony Convictions Mandatory exclusions last 5 years. (It can be indefinite if the facts warrant). By law, the OIG excludes any individual or entity convicted of the criminal offense from participation in all federal healthcare programs. At the conclusion of the exclusion period, the individual or entity must apply for reinstatement at the federal and state level. It is not automatic. Permissive Exclusion: Misdemeanor Convictions Permissive exclusions can be up to 5 years (typically 1-3 years). The OIG has discretion on whether or not to exclude individuals or entities on a number of grounds. The discretion falls to the courts to determine if they will be removed from play. At the conclusion of the exclusion period, the individual or entity must apply for reinstatement at the federal and state level. It is also not automatic. The Ultimate Guide to Exclusions 12

13 Definition of an Exclusion Fraudulent Activities Exclusions are a severe form of a sanction. An exclusion is the result from the following fraudulent activities: Did you know? Approximately 50% of providers on the OIG List of Excluded Individuals and Entities (LEIE) are derived from their license being sanctioned or revoked. That s a lot! Substance or alcohol abuse Patient abuse or neglect Sexual assault Healthcare-related fraud and abuse, theft or other financial misconduct Medicare or Medicaid Fraud, as well as other offenses related to the delivery of items or services under Medicare, Medicaid, CHIP or other state healthcare programs Unlawful manufacture, distribution, prescription or dispensing of controlled substances Healthcare fraud other than Medicare or a state healthcare program Fraud in a program (other than a healthcare program) funded by any federal, state or local government agency Suspension, revocation or surrender of a license to provide healthcare for reasons bearing on: professional competence, professional performance or financial integrity Provision of unnecessary or substandard services Submission of false or fraudulent claims to a Federal healthcare program Engaging in unlawful kickback arrangements Defaulting on health education loan or scholarship obligations Controlling a sanctioned entity as an owner, officer or managing employee The Ultimate Guide to Exclusions 13

14 Definition of an Exclusion What Leads to an Exclusion? As described above, there are a number of factors that can lead to a person or entity being excluded as well as some indicators that an exclusion may be coming. One such possible cause and indicator is a sanction on a healthcare provider license. A sanction from a healthcare disciplinary or licensing board can have significant consequences - including a spot on the OIG exclusion list or debarment list. The consequences for sanctions vary depending on the severity of the incident. Consequences A sanction issued by a state professional license board against an individual s license is an administrative action taken against the individual. Such sanctions can be attributed to a restriction placed upon the license and can include a revocation of the license. Licensing Boards can place a sanction on the license if the convicted individual s offense involves healthcare fraud and abuse, patient abuse, substance abuse or other related offenses. The federal OIG list is available at: oig.hhs.gov Prior to a healthcare professional receiving a sanction, a due process hearing takes place at the license or disciplinary board and/or the excluding agency. Thus, the individual has an opportunity to present his/her case. Upon issuance of a penalty, sanction or disciplinary action, such an individual s license may be restricted, revoked or suspended. This process can take months, and even years, to complete. The consequences for sanctions vary, depending on the severity of the incident. Exclusions are a severe form of administrative sanction, ending with the OIG issuing an exclusion and therefore placing the individual or entity on the OIG exclusion list. This means a provider will be prohibited from participating in federal healthcare program reimbursements. The Ultimate Guide to Exclusions 14

15 Fines & Penalties Penalties for Hiring or Doing Business with an Excluded Individual or Entity Doing business with an excluded individual or entity? Brace yourself for a plethora of fines! By law, the healthcare organization is responsible for all fines associated with employing or contracting with an excluded person or entity. From there, the OIG will assess civil fines and monetary penalties. The penalties for allowing services to be performed by, and billed to the CMS, by an excluded individual or entity can include: $10,000 per each item claimed or services provided Treble damage (3 times the amounts claimed to CMS for reimbursement) Possible program exclusion of the healthcare organization Possible loss of right to bill CMS for services rendered Possible additional fines for filing false claims under False Claims Act (Penalties up to $11,000 per claim, and possible placement in a Corporate Integrity Agreement with the OIG) Possible criminal fines and/or jail time The Ultimate Guide to Exclusions 15

16 Fines & Penalties Federal Reimbursement As we mentioned before, the government forbids federal reimbursement, whether direct or indirect, for goods provided or services rendered by an excluded individual or entity. This includes reimbursement for salaries, benefits or items claimed/billed by licensed healthcare providers or administrative personnel. Also, a healthcare organization cannot purchase goods or services from an entity or vendor that is excluded. With that said, if you, the employer, submit a claim for and/or receive federal healthcare reimbursements either directly or indirectly for that individual or entity, your organization is subject to civil fines and monetary penalties. Note that the average fine for hiring or contracting with an excluded person or entity is $100,000 per person or entity, with more recent cases indicating a steady increase to roughly $197,000 per person or entity. *See CHIRP on page 26 for more details. Generally speaking, the amount typically assessed in fines, if the OIG initiates the investigation (such as in an audit), is 3 times the amount of all damages. The silver lining lies in the recommended self-disclosure process, which, in most cases, reduces the multiplier to 1.5 times the amount of all damages. The Ultimate Guide to Exclusions 16

17 Fines & Penalties All You Need to Know About Self-Disclosing to the OIG You might hesitate to self-disclose fraud and exclusions to the OIG due to the time-investment and immediate fines; however, according to the OIG the process does not take as long as you might think. On average, the self-disclosure process from beginning to end takes just 12 months. However, when you consider the benefits of a self-disclosure, including the potential for reduction in civil fines and penalties, the process and the time it takes is well worth the effort. The last time the OIG issued an updated Self-Disclosure Protocol in 2013, they stressed the advantages of disclosing violations rather than having the OIG sniff them out. Self-disclosing beats having the OIG pursue your organization in a False Claims Act violation, fraud investigation or other related infractions. Advantages of Self-Disclosing The advantages to self-disclosing might surprise you. Take a look at these two reasons to self-disclose to the OIG: 1. Self-reporting would presumptively indicate an effective compliance program, removing the need for a Corporate Integrity Agreement (CIA) to get involved. As a result, you ll see reduction in major and unnecessary expenses that come with complying with the burdens required by a CIA. 2. The OIG formalized the process of reducing the multiplier of damages from 3 to 1.5. (3 times is the amount typically assessed if the OIG initiates the investigation/case). Although it s never fun to tattletale on yourself, following best practices certainly has its advantages. Remember, you can always visit the OIG s website for more information regarding the OIG exclusions database (see page 7). The Ultimate Guide to Exclusions 17

18 Differences Between the Exclusion Databases Understanding the differences between the exclusion datasets in the healthcare compliance industry can be overwhelming at times. To clarify, there are two main federal exclusion lists and 38* state Medicaid exclusion lists. All of these exclusion lists need to be individually cross-checked and monitored on a monthly basis in order to remain compliant. To make it even more complicated, not all of them share the same data with the OIG on a timely basis, let alone with each other. The most familiar safeguard for our industry is the OIG List of Excluded Individuals and Entities (LEIE). The LEIE, along with the other federal datasets, exists to inform the healthcare industry of currently excluded individuals, likely due to an offense related to fraud or abuse. Excluded individuals or entities can be found on federal or state exclusion lists. Don t forget state Medicaid Fraud Control Units (MFCU) also have Medicaid exclusion lists! The current exclusion lists include: OIG List of Excluded Individuals and Entities (LEIE) SAM (GSA exclusion list, includes EPLS) The state Medicaid lists The Ultimate Guide to Exclusions 18

19 The Difference Between the Exclusion Databases OIG Exclusion Lists/LEIE History This list has been in existence since the early 1990 s and is a compilation of those persons and/or entities that have been excluded from participation in the federal healthcare dollar programs. The list was designed to include all exclusions across the country. However, audits of the OIG show that it is missing up to 61% of exclusions at the state level. A person or entity becomes excluded, or sanctioned, and is placed on a list maintained by the OIG called the List of Excluded Individuals or Entities (LEIE). The federal list is available at The LEIE contains just the exclusion actions taken by the OIG. Today, the OIG List of Excluded Individuals/Entities has approximately 60,000 currently excluded individuals and entities. Further, according to Performance Standard 8, all state Medicaid Fraud Control Units (MCFU) are required to report any action it takes involving terminations and/or exclusions within 30 days of its action to the OIG. Searching the LEIE To search the list, you need a last name and first name. If a possible name match is found, then you will be asked to click the Verify button and enter the SSN to determine a match. This is pretty simple to navigate. You can even download the database and build your own search engine to conduct searches in bulk. *The OIG LEIE list is updated once a month. In addition, many cases include a National Provider Identifier (NPI) as an additional identifier to match against. If the individual held a professional license, that information and the Date of Birth can also be found in many cases. The Ultimate Guide to Exclusions 19

20 The Difference Between the Exclusion Databases GSA SAM Overview The GSA or General Services Administration, is the federal entity that excludes companies and individuals from receiving federal contracts. In addition to being excluded at the OIG-LEIE, an individual or entity can also be debarred or sanctioned at the GSA - SAM which includes the Excluded Parties List System (EPLS). The GSA administers all procurement databases, including SAM. SAM now houses the old Excluded Parties List System. So SAM is the GSA go-to! GSA administers EPLS and SAM, both of which contain debarment actions taken by various federal agencies, including exclusion actions taken by the OIG. This database also contains the old GSA EPLS as well as OIG exclusions. The Ultimate Guide to Exclusions 20

21 The Difference Between the Exclusion Databases SAM History SAM, the System for Award Mangement, was created as a result of the passage of the Affordable Care Act. The ACA tasked the government to create more encompassing federal data sets to help companies identify vendors that have federal contract compliance issues and/or procurement contract issues. In the case of the SAM, the dataset adds the Government Services Administration (GSA) and the Excluded Parties List System (EPLS) of debarred and sanctioned persons and companies. The EPLS list consists of federal contractors who have been debarred, sanctioned or excluded due to contracts or other fraud. Now that SAM includes GSA s EPLS list, healthcare companies can gain access to a broader database of other federal debarred lists. populated by other federal agencies and it is designed to provide one single search for such actions. It simply adds agency reported actions and is dependent on the agency for accuracy, timely records as well as reinstatements. SAM collects debarred, sanctioned and excluded parties that are reported to it by federal agencies. In essence, it is an aggregator of other agency records. It is a great additional source to search as a part of a broader exclusion monitoring process. However, SAM does not have any direct authority to fine a company if it does business with an individual or entity that is on their list. Purpose SAM s purpose is to prevent companies from doing business with an individual or entity that have been debarred, sanctioned or excluded by a federal agency. The SAM data is The Ultimate Guide to Exclusions 21

22 Industry Best Practices Conduct a pre-employment background check or pre-commencement of billing for the services or items purchased from a third party vendor against the exclusion list When an employer combines a background check of the exclusion list with state Medicaid exclusion lists - as well as license verification, education verification, employment verification, a social security number validation, and appropriate criminal records history - it can safely rely upon certain protections against negligent hire. Check all of your employees and entities against all available exclusion lists on a monthly basis Self-disclose any exclusions found to the OIG Where to look, you ask? That s where this all gets a bit tricky. According to the PPACA Section 6501, if you are excluded in one state, you are now considered excluded across all 50 states. So, first you need to check the OIG s List of Excluded Individuals and Entities (LEIE) Secondly, you need to check the SAM list (which includes GSA and EPLS) Lastly, you need to check all available state Medicaid exclusion lists The Ultimate Guide to Exclusions 22

23 Industry Best Practices Who Needs to be Monitored? 1. Individuals 2. Third party entities (i.e. vendors) 3. Owners of the third party entity 4. Referring physicians The OIG can exclude an individual and a third party entity/vendor. Thus, the OIG LEIE list should be checked each month for an individual as well as an entity/third party vendor. Unfortunately, the owner(s) of the entity/third party vendor are often forgotten. Who is Considered the Owner? From the OIG Guidance perspective, an owner with 5 percent or more of the company will land on their radar screen. In fact, the OIG Work Plan for 2014 and 2015 affirm that the OIG is studying how healthcare organizations and states collect ownership in enrollment and prior to contracting in Medicaid and Medicare. It is important to note that most states have a state Medicaid Exclusion list. Each state updates its list at different intervals and in different formats. Employers need to search these, in addition to the OIG- LEIE and the GSA -EPLS (now Further, the provider may not seek Federal healthcare program payment for any services, including the administrative and management services described above, furnished by the excluded owner. Our Recommendation A statement from your third party entities which affirms that owners of 5 percent or more do not perform administrative and management functions might be used as a reason not to include owners in your monthly exclusion monitoring. However, as a precaution, we recommend running monthly exclusion monitoring on all owners of the entities you re in business with through Medicare and Medicaid dollars. The Ultimate Guide to Exclusions 23

24 Industry Best Practices How to Get Off the Exclusion List So you, your employee or entity is excluded. Your name is posted on the OIG s List of Excluded Individuals and Entities (LEIE), and the exclusion is following you around like a scarlet letter wherever you go, preventing you from working for or with any healthcare organization that bills Medicare/Medicaid. But there s some good news in most cases, if you paid your dues, you can be reinstated. Reinstatement of excluded entities and individuals is NOT an automatic process once the specified period of an exclusion ends. Most exclusions have a specific term length, often 5 years. At the end of your OIG exclusion term, you must apply for reinstatement and receive authorize notice from the OIG that your request was granted. Excluded providers may begin the process of reinstatement 90 days before the end of the excluded period. Exclusions, on average, are five (5) years in length. Premature requests for reinstatement will not be considered, so be mindful of when to apply. To apply for reinstatement, send a written request to the OIG at the address below: HHS, OIG, OI Attn: Exclusions P.O. Box Washington, D.C Upon receiving your written request, the OIG will then provide Statement and Authorization forms that you must complete, sign, and return. The OIG will evaluate your submission and will send a written notification of their final decision on reinstatement directly to you. This process typically requires up to 120 days to complete, but can take longer. If the OIG grants you reinstatement via written notice, then you re off the list! However, it s always good to double-check. If the OIG denies your written request for reinstatement, you may reapply after 1 year. While the process of reinstatement can be long and arduous, following the established procedures in order (and at the right point in time) can effectively get your name off the OIG exclusion list. Simply follow directions, fill out the forms in their entirety, and don t apply for reinstatement before 90 days prior to the end of your excluded term, and you should be alright. Best of luck! The Ultimate Guide to Exclusions 24

25 Introduction Additional Resources Here at ProviderTrust, we believe in sharing innovative ideas and collaborating with others. We love seeing people succeed! That s why, Help Others Grow & Succeed, is a ProviderTrust core value that guides everything we do. As a part of this effort, we re constantly looking for ways to provide our readers with fresh, relevant content! Take a look at the resources on the next few pages to discover more ways to learn as a healthcare compliance professional. ProviderTrust s Healthcare Compliance Blog Your source for healthcare compliance news, advice from industry experts and all things related to OIG exclusions. Subscribe today! Related topics: The Cure to Vendor Procurement Fraud Differences in the OIG-LEIE and GSA Exclusion Lists How to Get off the OIG Exclusion List Human Resource Compliance - One and the Same Sign up for our free compliance webinars to receive advice from industry experts, stay up-to-date with regulations, and more! The Ultimate Guide to Exclusions 25

26 Additional Resources ProviderTrust created CHIRP, the Compliance Healthcare Index Report, to raise awareness of the potential risk to healthcare organizations who do not comply with regulations regarding employment practices. CHIRP identifies gaps in public records that can be misleading or even result in possible exposure to liability. CMS programs (Medicare, Medicaid, TriCare, and CHIPS) will not provide reimbursement to facilities that employ any excluded individuals or companies that are found in national and state exclusion databases. CHIRP seeks to shine a light on a small portion of all this data by providing an accurate picture of exclusion records in the United States. Click Here to Download CHIRP Now! Download Your Exclusive CHIRP Report Today! The Ultimate Guide to Exclusions 26

27 Introduction ProviderTrust Solutions At ProviderTrust, we simplify healthcare compliance in order to help you protect your organization. Some of our many features designed for you include: Automated Exclusion Monitoring With ProviderTrust, you can search the OIG exclusion list, the SAM database and all available state Medicaid exclusion lists with ExclusionCheck. Automated Vendor Monitoring Put vendor exclusion monitoring on auto-pilot! VendorProof automates the checking, ongoing monitoring, reporting, and notifying you of any possible issues. Want More Details? Let s Chat! Whether you need answers to your exclusion monitoring questions or you re simply interested in our solutions - we re here to help! Call ! You may also visit our website: providertrust.com/contact The Ultimate Guide to Exclusions 27

28 Additional Resources 3 Ways to Dig Deeper Culture of Compliance Monthly Webinars Stay connected with the latest healthcare compliance updates and regulations by joining us for one of our upcoming webinars. Gather valuable information from expert hosts and guests, and have your questions answered during our Q&A session. Click here to register for the next webinar in the series! Follow Our Resource Page The ProviderTrust Resource page is a one-stop shop packed with free information to help healthcare professionals build their knowledge and connect with industry standards via ebooks, webinars, case studies, and more! Click here to take a look around! Discover How to Automate Our VendorProof solution helps you stay on top of all vendor exclusion monitoring, alleviating hours of time and attention. With a simple setup and onboarding process, you ll be confident that you won t be doing business with excluded entities. Click here to learn more and get started! Enjoyed this ebook? Share it with your friends! Facebook LinkedIn Twitter Let s Connect! facebook twitter linkedin The Ultimate Guide to Exclusions 28