Protecting Your Healthcare Business: Understanding OIG Checks and Vendor Screening

If you work in the US healthcare industry, you know that patient safety comes first. However, running a medical practice, hospital, or healthcare service isn't just about treating patients; it is also about following the rules set by the government. One of the most critical rules involves knowing exactly who you are hiring and who you are doing business with.

This brings us to some very important terms: OIG check, OIG exclusion, and vendor screening. While these might sound like complicated legal terms, they are actually quite simple concepts that keep your business safe and your patients protected.

What exactly is the "OIG Exclusion List"? The "OIG" refers to the Office of Inspector General, an agency within the U.S. Department of Health and Human Services (HHS). The OIG's mission is to combat healthcare fraud and abuse in government programs such as Medicare or Medicaid.

As part of the OIG's effort to fulfill its mission, it maintains a list of individuals/entities that are excluded from receiving payment for federal healthcare services. This list is referred to as the  Exclusion List OIG (officially the "List of Excluded Individuals/Entities" or LEIE). In its most simple terms, this is a national "Do Not Hire" list for healthcare providers.

Individuals listed on this exclusion list are put there because of their actions associated with providing healthcare. Some examples of actions that can lead to being placed on the exclusion list include:

 - committing fraud against Medicare or Medicaid

 - abusing or neglecting patients

 - having felony convictions relating to healthcare or 

 - engaging in financial misconduct.

What is an OIG Check?

An OIG check is the process of looking up a name on that exclusion list.

Here is the golden rule of healthcare compliance: You cannot employ or contract with anyone on the exclusion list if you accept federal money.

If you hire a nurse, a billing clerk, or a doctor who is on the exclusion list, and you bill Medicare or Medicaid for their services, you are breaking the law. The government will refuse to pay for those services, and they will demand you pay back any money you already received.

An OIG exclusion isn’t only a minor offense; it is a serious violation with significant monetary consequences. If your organization employs an excluded person, the OIG may assess your agency a monetary penalty for each claim submitted by that person or for each item or service provided by that person; these are considered civil monetary penalties (CMPs) which can financially destroy a small medical practice.

In addition to financial consequences, OIG exclusions are about trust. If the individual was excluded due to his/her past abuse of patients or theft of drugs, you do not want that person employed in your office. Thus, running OIG exclusion checks on all employees is a moral responsibility to protect patients from being harmed by potentially dangerous employees.

An OIG exclusion isn’t only a minor offense; it is a serious violation with significant monetary consequences. If your organization employs an excluded person, the OIG may assess your agency a monetary penalty for each claim submitted by that person or for each item or service provided by that person; these are considered civil monetary penalties (CMPs) which can financially destroy a small medical practice.

In addition to financial consequences, OIG exclusions are about trust. If the individual was excluded due to his/her past abuse of patients or theft of drugs, you do not want that person employed in your office. Thus, running OIG exclusion checks on all employees is a moral responsibility to protect patients from being harmed by potentially dangerous employees.

Don't Forget Vendor Screening

Many healthcare leaders remember to check their doctors and nurses, but they often forget about the companies they buy supplies from. This is where vendor screening comes in.

An "entity" (a business) can be excluded just like a person can. If you hire a staffing agency, an ambulance company, or a medical supply vendor that is on the exclusion list, you face the same fines as you would for hiring an excluded employee.

Vendor screening ensures that every third-party company you work with is in good standing with the government.

The Bigger Picture: Sanction Verifications 

The OIG (Office of the Inspector General) list is probably the biggest name in sanction verification databases. But, it is not the sole list. Other sanction verification databases include SAM.gov (System for Award Management), as well as approximately 50 state Medicaid exclusion lists. 

A complete sanction verification involves checking all of these databases. A physician may not be federally excluded from working for the OIG, but they may have lost their medical license in a single state. If you are only checking the OIG sanction list, you would miss out on an important red flag. A proper sanction verification will provide you with a complete portrait of an employee’s background.

Administrating The System

At this point in time, you are either thinking, "Wow, that's a lot of work!" or "This is going to take forever!" You are correct on both counts. Entering hundreds of names into Multiple Governmental Websites every month is both labor-intensive and has a high susceptibility for "human error".

However, you cannot afford to skip this step. The OIG also recommends checking these lists each month as the lists are constantly being updated.

This can be managed and completed easily if you utilize a service provider to complete this task for you. Companies such as Venops or others can automate the process of uploading a list of employees and vendors and provide instant results to show you if any of those individuals or entities are on an exclusion or sanction list.

Using a service eliminates the "human error" factor, and provides a paper trail to demonstrate that you performed due diligence and completed checks. If you get audited for any reason, you can provide them the specific date that you completed the checks and that your employees did not exist on the sanctions or exclusion lists.

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Conclusion

In the US healthcare system, compliance is the foundation of success. Understanding the exclusion list OIG and performing a regular OIG check is essential for protecting your revenue and your reputation.

By incorporating thorough sanction checks and vendor screening into your monthly routine, you ensure that everyone entering your facility—from the head surgeon to the supply delivery driver—is safe, qualified, and allowed to be there. Whether you do it manually or use a helpful service, make sure these checks are a priority for your organization.