OIG/GSA Sanction Screening

OIG Compliance NOW is a private company comprised of a team of seasoned, qualified experts dedicated to ensuring that your organization is in total compliance with OIG/GSA compliance requirements, including adherence to all applicable federal/state regulations and guidances.

The U.S. Department of Health & Human Services (HHS) is responsible for managing and monitoring reimbursement practices for its various programs, including Medicaid and Medicare. One of its divisions, the Office of the Inspector General (OIG), is charged with protecting the integrity of HHS programs, including the health and welfare of the beneficiaries of those programs. For many years, under a Congress mandate, the OIG has managed a program to exclude certain individuals and entities from participating in Federally-funded health care programs, as per section 1128 of Title XI of the Social Security Act. Excluded entities are not permitted to bill government programs for services rendered, and entities who employ excluded individuals are not permitted to bill for services rendered by those individuals.

Many health care institutions are financially dependent on reimbursement of monies from federal and state healthcare programs, such as Medicaid and Medicare, to fund their business operations. This includes organizations such as hospitals, physicians, home health agencies, clinical laboratories, third-party billing companies, durable medical equipment companies, hospices, nursing facilities, ambulance suppliers, Medicare Advantage institutions, pharmaceutical/biologic/device manufacturers, and other providers of healthcare products/services that qualify for reimbursement. In addition, these health care institutions are supported by numerous vendors and contractors in their daily business operations, which means that vendor and contract organizations must also be concerned with the employment of excluded individuals.

In September 1999, the Office of Inspector General (OIG) released a Special Advisory Bulletin entitled The Effect of Exclusion From Participation in Federal Health Care Programs. This bulletin outlined the nature of exclusions and the effects of employing/contracting with excluded parties, and encouraged all health care institutions to conduct periodic sanction screening. Additional regulations and guidances now exist to assist health care institutions in their understanding of and compliance with the OIG exclusions program. Click here to see a summary of Sanction Screening Regulations.

The consequences of employing or contracting with an excluded individual or entity are serious, and include the following:

  • Reporting and repayment of all monies received by the excluded individual or entity, within 60 days

  • $5,500 to $11,000 fine for EACH item/service claimed or “caused to be” claimed Treble damages, or three times the amount of the program’s loss

  • Extension of the existing exclusion period, or a new exclusion imposed by OIG for the individual/entity

  • Possible criminal false claim situation under FCA (False Claims Act), which is a separate basis for administrative sanctions and exclusions

    OIG Compliance NOW was created to assist health care institutions with this potentially costly area of compliance. Click here to learn how our program works to keep your organization safe and in compliance.