Introduction
When it comes to regulatory compliance, most hospice providers believe they’ve got their bases covered with routine background checks and credential verifications. But here’s the truth: relying on these alone might leave your organization exposed to significant legal and financial risks. Enter OIG exclusion checks—an often misunderstood but indispensable component of hospice care compliance.
What makes OIG exclusion checks so vital? They do more than just flag individuals with a history of healthcare fraud. They also identify entities barred from participating in federal healthcare programs, a distinction that standard screening methods often miss. Even unintentional noncompliance could result in heavy penalties and reputational damage.
In this blog, we’ll demystify what OIG exclusion checks include, shed light on their limitations, and explain why they’re a non-negotiable for safeguarding your hospice’s integrity and operational success. Ready to find out if your organization has a blind spot? Keep reading.
What Are OIG Exclusion Checks?
OIG exclusion checks are screenings performed to ensure that your hospice care organization does not employ or engage with individuals or entities excluded by the OIG. These exclusions typically arise from violations such as:
- Medicare or Medicaid fraud
- Patient abuse or neglect
- Felony convictions related to healthcare fraud, theft, or unlawful distribution of controlled substances
Entities or individuals on the exclusion list are barred from participating in federally funded healthcare programs, meaning your organization cannot bill for services rendered by these individuals or entities.
What Do OIG Exclusion Checks Include?
OIG exclusion checks focus on verifying whether an individual or entity is listed in the List of Excluded Individuals/Entities (LEIE) maintained by the OIG. Key aspects include:
- Verification of Names: These checks match employee, contractor, or vendor names against the LEIE to identify exclusions.
- Details on Exclusions: The LEIE database provides specific information about the reason for exclusion, dates of exclusion, and whether the exclusion is partial or total.
- Search Variability: Advanced tools can perform variations of name searches, ensuring aliases or spelling errors don’t result in missed exclusions.
What Don’t OIG Exclusion Checks Include?
While comprehensive, OIG exclusion checks are not a one-size-fits-all compliance solution. Here’s what they don’t cover:
- Criminal Background Checks: OIG exclusion checks focus on specific exclusions but do not uncover broader criminal histories or convictions unrelated to healthcare programs.
- State-Specific Exclusions: Many states maintain their own exclusion lists, which may not overlap with the federal LEIE. Failing to check state databases could result in missed exclusions.
- Continuous Monitoring: A one-time OIG exclusion check is insufficient. Regular monitoring is necessary to ensure ongoing compliance as new exclusions are added to the LEIE.
- Non-Healthcare-Related Issues: The checks won’t flag concerns unrelated to federal healthcare program violations, such as financial mismanagement or workplace misconduct.
Why Are OIG Exclusion Checks Crucial for Hospice Care?
Hospice care organizations often rely on government reimbursements through Medicare and Medicaid, making compliance with OIG regulations non-negotiable. Even a single overlooked exclusion can result in:
- Fines and Penalties: Organizations face steep financial penalties for employing excluded individuals or entities.
- Reputational Damage: Compliance violations can erode patient and community trust.
- Program Exclusion: Noncompliance could lead to the hospice itself being barred from federal programs.
Best Practices for OIG Exclusion Checks
To ensure your hospice care organization is fully compliant, consider adopting these practices:
- Implement Comprehensive Screening: Use software that checks the LEIE alongside state exclusion databases for thorough coverage.
- Perform Regular Checks: Conduct checks at the time of hiring, and schedule periodic re-screenings to capture new exclusions.
- Train Your Compliance Team: Educate staff on the importance of OIG exclusion checks and provide training on how to perform and document them effectively.
- Maintain Detailed Records: Keep meticulous records of all exclusion checks and any corrective actions taken.
Conclusion
OIG exclusion checks are a cornerstone of compliance for hospice care providers, but they are not the full picture. By understanding what these checks include—and what they don’t—you can build a more robust compliance framework that protects your organization from risks and upholds the highest standards of care.
If you’re ready to strengthen your compliance efforts, start with a systematic approach to exclusion checks—and stay vigilant. Compliance is an ongoing process, not a one-time task.