Corporate Compliance

Identifying excluded individuals and entities

Healthcare Auditing Weekly, August 24, 2004

When reviewing your organization's process for identifying excluded individuals and entities through the Office of Inspector General (OIG) and General Services Administration (GSA) sanction lists, it is important that you understand the following regulations:

  • The OIG imposes exclusions under sections 1128 and 1156 of the Social Security Act

  • A section of the Balanced Budget Act authorizes the government to impose civil-monetary penalties (CMP) on providers and entities that employ or contract with excluded individuals or entities to provide items or services to federal healthcare beneficiaries

  • Under the provisions, providers face CMPs for submitting claims to the government for items or services provided directly or indirectly by excluded individuals or entities

  • In addition to CMPs, facilities face a fine of up to three times the amount claimed, plus possible program exclusion

    To learn more about these regulations, order the book "Hospital Auditing and Monitoring: Sample Programs for Key Risk Areas," published by HCPro, Inc. This binder and CD-ROM are filled with actual audit programs used by auditors and compliance officers in the field.

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