Keeping Your Practice Safe: The Importance of OIG Screening

If you operate a medical practice (e.g., a hospital or dental office), you have a lot on your plate. You are responsible for meeting the needs of your patients and managing your staff, plus a ton of paperwork. However, one of the most important tasks you'll need to accomplish is conducting an OIG Check for financial reasons.

The OIG Exclusion list and OIG Screening are terms you may not be familiar with, so don't panic! You're not the only one; most people just don't know these terms. But if you ignore them, it could lead to significant future expenses. Let's explore what these terms truly mean using plain English!

OIG Exclusion Overview

The Office of Inspector General (OIG) is a federal agency associated with HHS – The United States Department of Health & Human Services – whose role includes the investigation of fraud, waste and abuse in conjunction with the administration of the Medicare and Medicaid programs.

If an individual or entity engages in fraud or another business-practice violation, the OIG will add them to an 'exclusion list.' This list is referred to as the OIG Exclusion List, or the List of Excluded Individuals/Entities (LEIE).

Individuals/entities placed on this list cannot receive reimbursement from any US Federal Health Care Programs. As such, an individual that is placed on the OIG Exclusion List shall not work for you, prescribe medication under your plan, or provide any type of service subject to reimbursement by the Medicare or Medicaid programs.

Why Should You Conduct an OIG Check? 

To illustrate: You have just hired a new nurse or a contractor to do some fieldwork at your medical clinic. Everything about them appeared to be good, including their resume, and were extremely helpful when interviewed. But what if, unbeknownst to you, your new nurse has been found guilty of criminal healthcare fraud in the past and is currently listed on the OIG's List of Exclusion? 

If you subsequently hire them, and then submit a Medicare billing to the government for their work, you have committed a crime. Even if you were not aware that they were excluded from being able to bill the government, you are still being held responsible for any charges billed as a result of their actions. Therefore, it is critical that you conduct an OIG check on all potential employees. 

Simply put, an OIG check consists of searching the OIG's database to check whether or not an employee is listed there as excluded from being able to work in the medical field.

What is OIG Screening?

The OIG Check is typically done just one time (when hiring), but OIG Screening is a continual process.

One of the most common misconceptions about the OIG Screening process is that once you have hired a "clean" employee, you do not have to do any further OIG Checks. This is untrue. Hundreds of people are added to the "exclusion list" every week. By failing to routinely check your employees, it is possible that you may have an employee today, and next month that employee could have been excluded from the program.

OIG Screening is checking your entire employee staff against the OIG Exclusion list on an at least monthly basis; many experts recommend more frequent than monthly checks.

OIG Screening: Why It’s Important

You may wonder “Why do this?” The answer is: To avoid penalties that can add up quickly.

If you hire an individual who is excluded from participation in Medicare or Medicaid, and then the government becomes aware of this, it can issue a penalty that could reach into the thousands of dollars for each individual file submitted. In addition to being fined, your ability to bill for services may be terminated, which could lead to the loss of your business. 

Complying with OIG Screening

The OIG Screening process is not very complicated. You can conduct a manual search for free through the LEIE database found on the OIG website. However, checking the database for dozens of employees on a monthly basis can be very time consuming.

Many healthcare providers now utilize automated software to perform OIG Checks and screenings. This software automatically reviews the database and alerts you if a match is found.

Final Thoughts

Protecting your practice from fraud isn't just about spotting bad guys; it’s about following the rules. By performing regular OIG Screening and ensuring every employee passes the OIG Check, you protect your reputation and your wallet.

Don't wait for an audit to discover you have an excluded employee on your payroll. Make screening a part of your routine today.