The Importance of OIG Exclusion List Screening in the Healthcare Industry

The healthcare industry is no stranger to strict regulations and compliance requirements. After all, the goal of regulations within healthcare is to ensure a baseline level of quality and safety.

Similar to how the pharmaceutical industry must ensure the quality and safety of the drugs it produces, hospitals must also create a safe and secure environment for the medical services they provide to the public – basically satisfied customers that help enable growth. And yet, many hospitals often overlook exclusions lists, which include mandatory bans on working with certain companies and individuals, also known as denied or restricted parties.

The Office of the Inspector General (OIG) publishes just one of the many exclusion screening lists that businesses in this space must consider. Let’s go over what the list is and why screening against it matters.

Export controls and exclusions screening are a consideration for businesses of any industry, but healthcare firms that work with a large number of suppliers and distributors and hire many professional physicians and staff need to be especially wary that they are not working with banned entities.

Ensuring that you comply with the OIG exclusion list matters for several reasons.

• You will be susceptible to civil monetary penalties (CMP).
• Partnering with companies or hiring individuals the government deems risky can compromise the safety and effectiveness of your product output or your medical services, thereby putting your patients and customers at risk as well.

Refer to the official List of Excluded Individuals and Entities (LEIE) to see which individuals, companies, and other entities are barred from participating in federally funded healthcare programs.

Keep in mind though that the LEIE is constantly being updated over time, so you will also need to screen the list on a regular basis to stay up to date with the changes. There are also other exclusions lists that need to be screened against, including GSA’s SAM, State Medicaid, OFAC and so on. These will be discussed in more detail later in this article.

There are two types of exclusions: mandatory ones that are required by law and permissive ones that are at the discretion of the OIG. Most reasons for admission to the list are:

• Poor track record of offering low-quality services.
• Patient neglect or abuse.
• Production or distribution of controlled substances and drugs.
• Federal healthcare program fraud, such as activities related to Medicare or Medicaid.
• Defaulting on obligations regarding health education loans.

Any entity on the OIG exclusion list may not receive payments for services completed through federal healthcare programs. However, they may still be able to receive benefits from those programs in certain circumstances.

The government has made it clear that medical businesses—whether they’re hospitals, research organizations, or others—are responsible for their own OIG exclusion list screening policies. Because of this, you should implement screening systems to reduce the risk of costly sanctions, fines, and reputational damage.

Because the OIG exclusion list is constantly changing, the challenge to organizations is keeping pace with the ongoing updates. This is important since entities might appear on the list today when they weren’t included before. Top performing companies rely on software solutions providers to help meet compliance requirements so that they can focus on their core business mission of satisfying customer demand and enabling growth.

Yes. Medical compliance can be a complicated topic. We’ve only scratched the surface of what exclusions hospitals and businesses in this field must pay attention to. For instance, in addition to the OIG Exclusion List, you also have similar requirements from the Drug Enforcement Administration (DEA) alongside the Office of Foreign Assets Control (OFAC) and various others.

One separate but still related list to consider is maintained by the General Service Administration (GSA), which intends to prevent fraud in the healthcare industry. Its System for Award Management (SAM) requires compliance with various databases, including the Excluded Parties List System (EPLS).

While there may be some overlap between SAM and the OIG exclusion list, the two are, indeed, handled by independent administrative organizations. Medical companies need to consider both when hiring or partnering with new entities.

For more comprehensive information about effective compliance in the healthcare industry, download our white paper or visit our Resource Center.

Not only are there many exclusions lists to keep track of, but it’s always best practice to screen on a regular basis and continually monitor your compliance, as these lists, including the OIG exclusion list, change regularly.

It can seem overwhelming. However, you don’t have to spend a prohibitively large chunk of the budget on compliance systems that are manual or in-house, as many third-party services allow you to scan new hires and partnerships with ease and cost-effectively. Start your search with Descartes.

Don’t run the risk of getting hit with government enforcement action. Find out today how our denied party screening solutions can help you achieve a comprehensive and efficient compliance program.

With features like automated and integrated denied party screening (that includes healthcare watchlists like the OIG exclusion list), compliance management workflows, and export document management, Descartes is a provider of an industry-leading suite of denied party screening, 3^rd party risk management solutions, as well as trade content for leading business systems, that can be integrated with minimal disruption.

Descartes Visual Compliance and Descartes MK Denied Party Screening solutions are flexible and modular, allowing organizations to pick the specific and exact functionality and content they need for their particular compliance needs and scale up later as and when necessary.

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