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Hotline NewsWhat are the Elements of an Effective School Hotline?
By: Cason Liles
(January 21, 2019): The value of a compliance hotline cannot be understated. The usage of an internal whistleblowing system, such as a hotline, has a direct correlation with a [...]
Are Hotlines Worthwhile? Just Ask HHS-OIG!
By Robert Liles
(January 5, 2018): Does your health care organization have a compliance hotline / fraud hotline in place? If not, it should implement one as soon as possible. As proof [...]
Elements of a Successful Compliance Hotline
1. Anonymity:
Employees should be able to provide their tips of wrongdoing anonymously. While all companies should strive to have open lines of communication, it is important to recognize that many employees [...]
| In-Depth ArticlesAre Hotlines Worthwhile? Just Ask HHS-OIG!
By Robert Liles
(January 5, 2018): Does your health care organization have a compliance hotline / fraud hotline in place? If not, it should implement one as soon as possible. As proof [...]
Pain Management Prescribing Practices and Audits
(August 16, 2017): Earlier this summer, the U.S. Department of Justice (DOJ) executed its most extensive “health care fraud takedown” to date, initially arresting 412 licensed healthcare providers, doctors, and nurses [...]
Advance Beneficiary Notice of Noncoverage
By Robert LilesHave you implemented the new “ Advance Beneficiary Notice of Noncoverage ” (ABN), required by the Centers for Medicare and Medicaid Services (CMS)? As CMS has noted, although the latest version [...]
Health Care Fraud to Remain a DOJ Priority
Exclusion News (May 22, 2017): By Paul WeidenfeldHealth Care Fraud will continue to be a high priority of the Department of Justice Kenneth Blanco, the Acting Head of the Criminal Division. [...]
The New “Seventh Element” of Compliance: Screening and Evaluating Employee Suitability!
The recently issued Resource Guide for Measuring Compliance Program Effectiveness, reconfigures the traditional formulation of the “Seven Elements of an Effective Compliance Program by making the “Screening and Evaluation of Employees, [...]
Excluded Dentist Pays Record $1.1 Million and Agrees to 50 Year Exclusion
Exclusion Violation by Dentist "Sends a Strong Warning"
February 1, 2017
By Paul Weidenfeld
The Office of the Inspector General's (OIG) announced last week that it had reached a settlement in excess of a [...]
OIG Issues Final Rule Expanding Exclusion Authority
By Paul Weidenfeld
January 23, 2017
On January 12, 2017, the Office of Inspector General published a final rule finalizing revisions to its exclusion authorities. The final rule makes changes to key definitions [...]
DOJ Announces $4.7B in FCA Recoveries: What Does It Mean?
DOJ Announces $4.7 billion in False Claims Act Recoveries
By Paul Weidenfeld
December 16, 2016
The "Third Best Year" in False Claims Act History?
The Department of Justice announced earlier this week that FY 2016 was [...]
OIG Continues to Step Up Enforcement of Exclusion Violations
Enforcement of exclusion violations by the Office of the Inspector General (OIG) continues to show rise with increases in both the number of cases and the size of the settlement recoveries [...]
What Medical Practices Need to Know About an OIG Exclusion
By Paul Weidenfeld [1] The Office of Inspector General (OIG) has steadily increased its enforcement of OIG Exclusion violations since the issuance of its Special Advisory stressing the effect of an OIG Exclusion in May, [...]
DOJ Doubles Down on False Claims Act Penalties!
By Robert W. Liles. August 3, 2016. The False Claims Act is the primary civil enforcement tool utilized by the federal government in its fight against fraud generally, and, in particular, Medicare and Medicaid [...]
Medicare Exclusion Checks Will be Audited by OIG
By Paul Weidenfeld
In October of 2015, the Department of Health and Human Services, Office of Inspector General (HHS/OIG) issued its “Work Plan: Fiscal Year 2016.” The purpose of the Work Plan [...]
How Compliance Hotlines Can Save Money!
Compliance Hotlines Can Save Money!
By Paul Weidenfeld, March 4, 2016. An essential element of all compliance plans is developing and promoting “effective lines of communications.” In support of that element, Health [...]
Who Is to Blame for Gaps in OIG and State Exclusion Lists? What Is the Impact on Providers?
The failure to report excludable offenses by state Medicaid offices and licensing boards is a longstanding issue for the OIG. Recent OIG audits and reports have confirmed these state failures to [...]
Southern District of New York Provides Clarity on “Identifying” Overpayments
In early August of 2015, the Southern District of New York (SDNY) provided insight as to when the 60-day clock for returning an overpayment begins to run under the Patient Protection and [...]
Exclusion Screening of Contractors and Vendors
Exclusion Screening of Contractors and Vendors
By now, providers should be aware that the Office of Inspector General (OIG) requires exclusion screening of contractors and vendors, in addition to employees, if they [...]
Exclusion Screening Basics for Providers
Exclusion Screening Is Mandatory
Providers of medical services that participate in Federal or State Health Care Programs are required to screen all of their employees, vendors, and contractors monthly to ensure that [...]
Medicare and Medicaid Exclusion Screening Compliance: A Challenging Problem with a Surprisingly Simple Solution©
Since August 2014, the Office of Inspector General (OIG) has collected roughly $3.75 Million in Civil Money Penalties (CMPs) in cases involving the employment of persons that have been “excluded” from Medicare. [...]
OIG's Updated Special Advisory Bulletin on the Effect of Exclusions
The Office of the Inspector General (OIG) Broadly Interprets Exclusion Regulations
OIG's Demonstrated Interest in Exclusion Screening and Forewarning of Increased Enforcement Efforts
By Paul Weidenfeld
The OIG's Special Advisory Bulletin on the Effect of [...]
HCFAC Report 2014: After Consecutive Record Years, Recoveries and Prosecutions Dip, but Exclusions Continue to Increase
The Health Care Fraud and Abuse Control Program1 (“HCFAC”) prepares detailed yearly reports which are sometimes viewed to be a barometer of fraud and abuse enforcement efforts. Valid conclusions can’t be drawn based on [...]
Current States With Separate Exclusion Databases
I. Medicaid Exclusion
Exclusion Screening, LLC conducts monthly checks of our clients' employees, contractors, and vendors against the OIG-LEIE, GSA-SAM, and all available state lists. Most providers understand that they have an [...]
What is an Exclusion Waiver and Who May Apply
We have previously discussed that once a provider is excluded he may not furnish items or services paid for by the the Federal health care programs until he is eligible to apply [...]
Who Should Be on my OIG Exclusion List?
I. Federal and State Agencies Conducting Audits
As many health care providers and suppliers have painfully learned over the last year, federal and state law enforcement agencies, along with many of the [...]
Which Exclusion Lists Need to Be Screened? What Is the Difference between Them?
There are two federal databases that list persons and entities that have been excluded from participating in federal health care programs or receiving federal contracts. Checking and verifying individuals on the List [...]
Must Haves for a Proper Exclusion Screening Process
At Exclusion Screening, LLCSM, we know the ins-and-outs of the exclusion screening process. In our opinion, an effective screening process requires some mandatory tools. To ensure that there are no holes [...]
How to Apply for Reinstatement
I. The Reinstatement Process
Most exclusions are imposed for a definite time period. The question for an excluded individual or entity is: What happens at the end [...]
CMP Liabilities: Why Are Some Much Higher Than Others?
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A quick review of the Office of Inspector General's (OIG) exclusion enforcement actions might make one wonder why the Civil Monetary Penalties (CMPs) for some entities are only $10,000 while others [...]
Gary Cantrell Testimony: Failures to Report Adverse Licensing Actions Leads to Gaps in the OIG-LEIE
HHS/OIG Deputy Inspector General Gary Cantrell testified earlier this year that States are failing to report all of the adverse actions taken by their Licensing Boards. He suggested that the “manner and [...]
CMS Finds Fault with Exclusion Information Sharing Between States
I. Take It from CMS: If You're Excluded in One State, You're Excluded in All States
Section 6401(b)(2) of the Affordable Care Act (ACA) required the Centers for Medicare and Medicaid Services [...]
2015 OIG Work Plan: Prevention of Grant Awards to Excluded Persons and Entities
By Paul Weidenfeld
I. Concerns of the 2015 OIG Work Plan
The Office of Inspector General (OIG) expressed concern regarding exclusion and suspension enforcement in its 2015 OIG Work Plan. The OIG announced [...]
OIG Provides Guidance on Disclosures for Conduct Involving Excluded Persons in the Updated Self-Disclosure Protocol
I. Provider Self-Disclosure Protocol: New Guidance Sheds Light on Disclosure
On April 17, 2013, the Office of the Inspector General (OIG) issued an updated Provider Self-Disclosure Protocol that many viewed as an attempt to [...]
OIG Proposes Amending Rules to Increase its Civil Monetary Penalty and Exclusion Authority
In May 2014, the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services published two proposed rules to implement provisions of the Affordable Care Act (ACA). [...]
What is an OIG Exclusion?
By Paul Weidenfeld
I. What is an OIG Exclusion?
An OIG Exclusion is a final administrative action by the Office of the Inspector General (OIG) that prohibits participation in any Federal Health Care Program. Exclusions are [...]
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   Elements Successful Compliance Hotline
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