Exclusion from federal health care programs is one of the OIG’s bigger enforcement hammers and the agency is ramping up its focus on this tool.
 
As we know from reading Fraud & Abuse Answers and Medical Practice Compliance Alert, a person who is excluded can’t be in the same room as funds from such programs as Medicare and Medicaid. OK, we’re exaggerating; but only a little bit.
 
To get an idea of the impact of exclusion, check out the agency’s new 19 page special advisory bulletin on exclusion. “Also, an excluded individual may not provide other types of administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to Federal health care programs.”
 
Exclusion applies even when federal funds go to an organization that isn’t excluded. So if Massive Physician Specialist Practice hires an IT tech who is excluded, the only way MPSP can avoid breaking the law is to stop treating patients who are covered by Medicare, Medicaid, TRICARE and so on.
We think it would be easier to check the OIG’s list of excluded individuals.