The Hidden Risks: Why a Monthly OIG Check is Non-Negotiable

Healthcare is an extremely active industry with a significant amount of documentation. It is easy to overlook your administrative responsibilities amidst all of your responsibilities for patient records, insurance claims, and payroll, but there is one thing that you simply cannot afford to ignore – the OIG Check.

Many healthcare practices check for a new hire only at the time of hire, after that, they will rarely if ever check for ongoing compliance. This is an incredibly risky decision. To avoid fines and/or legal issues, you must understand the continually evolving nature of OIG exclusions.

Here are the reasons why a one-time check does not suffice and what steps you can take to protect yourself from these risks.

The One-and-Done Error

Suppose that you have a new employee that is named Sarah and she is being hired on as your company's billing representative. On her first day of work, you run her through both a background check and an OIG check and both of them come back clear/clean. This is great news for you; she can start her billing right away.

After six months of working for you, Sarah is convicted of fraud from her previous employer and the government places an OIG exclusion against her and she can no longer bill with Medicare or Medicaid because she is excluded.

If you don’t perform a monthly OIG screening verification check then you would never discover that this has occurred and therefore continue to employ her and continue to bill through her for a period of time and in so doing commit a criminal act in civil court as you have continued to employ her without any knowledge of the criminal act.

The OIG Exclusion List is updated every month on a variety of new entries; therefore it is best practice in the industry to verify all employees within your organization on a monthly basis utilizing the OIG verification process.

Exclusion from OIG: It’s Not Just for Doctors

Many people incorrectly assume only physicians and nurses are at risk of exclusion from federal money via OIG; you need to be aware that this isn’t true.

The exclusions cover everyone who is compensated by Federal Healthcare Dollars, including:

Administrative Personnel such as receptionists, billers, or any staff directly responsible for the operation of the business.

Support Personnel including janitorial and cafeteria service personnel. These jobs can become part of the cost structure of a bundled federal claim.

Vendor and Contractor: If you contract with third-party vendors to maintain your IT and/or ambulance services, and if any of those vendors were excluded, they may cause you to have civil or criminal liability.

It’s important to check all vendors as you would your employees.

The Cost of Getting It Wrong

The penalties for employing someone with an OIG exclusion are severe. The government uses a system called Civil Monetary Penalties (CMP).

If the OIG finds out you employed an excluded person, they can fine you up to $20,000 for each service that person provided or ordered. On top of that, you can be fined three times the amount of the actual government remuneration.

For a small practice, these fines can be bankrupting. For a large hospital, they are a massive reputational blow.

How to Simplify the Process

Because checking every employee every month is time-consuming, many organizations use software or third-party services to automate the OIG Check.

However, if you are doing it manually:

1. Download the updated database from the OIG website every month.

2. Search for all employees and vendors.

3. Document everything. If you get audited, you need proof that you did the checks.

   
   

Summary

Don't treat compliance as an afterthought. OIG exclusion is a serious matter that changes in real-time. By committing to a routine, monthly OIG Check for everyone involved in your practice, you are building a shield around your business. It ensures that the funds keep flowing, the law is followed, and your patients are in safe hands.

In the busy world of healthcare, there is always a mountain of paperwork. Between patient charts, insurance claims, and payroll, it is easy to let some administrative tasks slide. However, there is one task you absolutely cannot afford to ignore: the OIG Check.

Many healthcare practices make the mistake of checking a new employee once during the hiring process and then never checking again. This is a dangerous gamble. To truly be safe from fines and legal trouble, you need to understand the changing nature of OIG exclusion.

Here is why a one-time check isn't enough and how to protect your organization.