Checking the LEIE, or List of Excluded Individuals or Entities, also known as the OIG Exclusions List, should be a fundamental piece of any medical practice’s compliance program. Yet so few people working in the healthcare space, even some compliance specialists, have never even heard of the list, or do not know how to check their employees or vendors on it.
Since our goal at First Healthcare Compliance is to protect medical practices from compliance risks, we have been covering this topic extensively. Yet there is always more to learn. As such, here are a few of the FAQs which your practice needs to know the answers to.
What is the Exclusions List?
The LEIE compiles individuals and corporate entities ineligible to participate in federal healthcare programs due to criminal activity or serious professional misconduct. Excluded persons are prohibited from furnishing administrative and management services that are payable by the Federal health care programs, including Medicare and Medicaid.
What happens when an organization run afoul of the Exclusions List?
Employing, or contracting with, an individual or entity on the list can prevent your organization from participating in federal healthcare programs. This includes both Medicare and Medicaid, and, in addition, potential Civil Monetary Penalties may apply to those organizations found in violation of the Exclusions list.
Who would be liable for organizations?
Both existing employees or vendors, and prospective employees or vendors.
How often should a practice check the List?
The LEIE updates monthly, and it is the responsibility of the organization to check on every employee and every vendor each and every month. Any contract, whether with an employee or a vendor, could appear, and is worth checking.
Checking the LEIE is an important piece of any medical practice’s compliance program. If the monthly check of all employees and vendors seems like a daunting task given the size of your practice, there are resources available to help. First Healthcare Compliance, as a part of our compliance management program, offers automatic screening of the LEIE for both employees and vendors.
As long as your practice knows that the list exists, checks it for any new employees or vendors, along with every month, then this can be a compliance requirement you can count as fulfilled.
