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.