OIG Exclusion List

All posts tagged OIG Exclusion List

Obtaining & Maintaining Your DMEPOS Company’s PTAN & Accreditation

by admin on December 4, 2020 No comments

By: Michael Silverman

Becoming a DMEPOS provider enrolled with Medicare is no small feat or undertaking. Whether you’ve started the business from ‘scratch’ or purchased an existing entity, you need to ensure that investment is protected through active and ongoing compliance measures.

To that end, I recently hosted a webinar with Matthew Gruskin, Credentialing Director at Board of Certification (“BOC”) to discuss some of the steps necessary to do so.  A copy of our presentation is available here.

Becoming “accredited” is a necessary precursor to being a Medicare Part B DMEPOS provider, and BOC is one of only nine Medicare approved DMEPOS accreditation organizations. Whether it’s through BOC or one of the other eight Medicare approved accreditation organizations, a DMEPOS business’s initial receipt of accreditation is really just a ‘first step’, insofar as if that accreditation is not maintained a DMEPOS supplier will lose their Medicare Part B billing privileges. Medicare’s DMEPOS Supplier Standard #22 specifically requires all enrolled providers to be accredited to receive and retain billing privileges.

A DMEPOS supplier must continue to abide by both Medicare’s DMEPOS Supplier Standards (which the National Supplier Clearinghouse is tasked with enforcing) and its Quality Standards (which accreditation organizations gauge compliance by) in order to stay in its good graces. Accreditation organizations conduct unannounced on-site surveys at least every three years and suppliers must also revalidate their enrollment with Medicare’s National Supplier Clearinghouse every three years, which results in an unannounced Medicare on-site visit.

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Hiring an Excluded Individual – Employer Beware!

by admin on November 13, 2019 No comments

hiring an excluded individualBy: Dave Davidson

It’s probably fair to say that most healthcare providers are aware of the federal Anti-Kickback Statute and the Stark Law (and if you’re not, please call me immediately!).  Those two laws, along with the False Claims Act, are the sources of the huge fines and penalties that make the headlines for governmentally discovered “fraud.”  However, there are a number of other regulatory provisions out there that the Office of Inspector General (OIG) is regularly policing.

One of these laws, with its origins in the Social Security Act, is the prohibition against providers hiring individuals or entities who have been excluded from participation in governmental health care programs such as Medicare or Medicaid.  Hiring an excluded person or company can expose a provider/employer to Civil Monetary Penalties, which can result in significant financial hardship to the provider.  And although this may seem like a simple rule to follow, recent enforcement activity shows that it may be fairly easy for an excluded person to “fall through the cracks” and wind up as your employee.

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Medicare Enforcement: CMS Has Expanded Its Ability to Revoke or Deny Provider Enrollment

by admin on September 10, 2019 No comments

medicare enforcementBy: Karina Gonzalez

A Final Rule recently issued by CMS will require Medicare, Medicaid, and CHIP (Children’s Health Insurance Program) providers and suppliers to disclose current and previous affiliations (direct or indirect) with a provider or supplier that: (1)  has uncollected debt; (2) has been or is excluded by the OIG (Office of Inspector General) from Medicare, Medicaid or CHIP, or (3) has had its billing privileges with either of these three programs denied or revoked. Such provider affiliations may lead to enrollment being denied if it poses a risk to fraud, waste or abuse.

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adminMedicare Enforcement: CMS Has Expanded Its Ability to Revoke or Deny Provider Enrollment