CJ Wolf
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Is your compliance program diligently performing exclusions’ checks against sanctioned individuals? It’s been reported that the risk of non-compliance equates to a minimum of $10,000 fine per billed item, with the average fine for hiring or contracting with an excluded person or entity is over $100,000.
For example, On March 21st, 2018, Pharmex Pharmacy, LLC, and Israel Weber (collectively, "Pharmex"), Lakewood, New Jersey, entered into a $314,205.76 settlement agreement with the OIG. The settlement agreement resolves allegations that Pharmex employed an individual who was excluded from participating in any Federal health care programs. OIG's investigation revealed that the excluded pharmacist provided items or services to Pharmex patients that were billed to Federal health care programs.
Additionally, on May 4th, 2018, Alameda Health System (AHS), California, entered into a $257,874 settlement agreement with OIG. The settlement agreement resolves allegations that AHS employed an individual who was excluded from participating in any Federal health care program. OIG's investigation revealed that the excluded individual, an eligibility clerk, provided items or services to AHS's patients that were paid for by Federal healthcare programs.
Unfortunately, these are just two examples of many.
If we can learn anything from case studies like these, it’s that exclusion checks are crucial to protect your organization’s bottom line. But manually checking all federal and state exclusion lists, every single month, for every individual and vendor participating in Medicare or Medicaid billable services for your organization can be overwhelming and time-consuming. Luckily, there’s a way to lessen the burden.
Download my free eBrief, Don't Worry, Sanction Checking Doesn't Have to Be a Nightmare, to get the full scoop on exclusion checks, including:
- Case Study Examples of What Not to Do
- Tips to Lesson the Burden of Exclusion Monitoring
- Details on Why Exclusion Monitoring is Necessary
Questions or Comments?