Penalty Amounts Stack Up for “Cases Involving Excluded Individual”

Cases Involving Excluded Individual$171,047.00, $96,020.00, $81,419.00, and $17,750.00!  These are the settlement amounts that providers made with The Office of Inspector General through April of this year alone.  “Cases Involving Excluded Individual”, a category found under the Civil Monetary Penalties and Affirmative Exclusions page at the OIG’s website, published four settlements totaling $366,236.00 due to the providers’ own failure. The providers themselves, their policies, procedures and staff failed to verify and enforce that all employees and contractors are not Excluded from participating in Federal health care programs.  One simple check should have been conducted prior to new hire; and, on an ongoing and monthly basis of existing employees. 

So far this year, at the top of the list is an Office Manager employed at a Skilled Nursing Facility, and an Admission Specialist at an Assisted Living Facility, separate cases but both based in Oklahoma. Third is a Registered Nurse employed also at a SNF, but in Tennessee. Lastly, a Counselor previously excluded from MaineCare working in Mental Health Services.  These four Excluded individuals provided services or items to patients that were billed by the provider to a Federal program, and that’s a no-no!  As one can readily determine, the choice to employ these people ended up being much more costly than their salary.  Add the amount they’ve been paid, benefits compensation, turnover cost plus the OIG settlement amount, this mistake makes for a pricey lesson. None of these individuals were forthcoming in disclosing their status of Exclusion, which also suggests another point regarding their character, but the providers could have easily checked and not left themselves exposed and open for such an OIG action.  The Excluded individual will not tell you when they desperately need a job!  Be also aware that there may be pending actions making it so worthwhile to conduct monthly Exclusion checks.

There are many companies and vendors that provide the service of running multiple exclusion checks on a monthly basis for a nominal fee.  However, like stated above, one simple check can be made by yourself, and if your office has not checked your employees, it takes less than a minute using the OIG Exclusion Checker.

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