All healthcare providers participating in federal programs (including Medicare) are encouraged to verify the OIG Exclusion List before hiring any staff—clinical or administrative—or engaging vendors whose services may be billed to Medicare, Medicaid, or other federal programs. Periodic checks of current employees and contractors are also recommended as part of routine internal audits. Maintaining these verifications helps ensure compliance and reduces the risk of civil penalties associated with employing or contracting with excluded individuals.
Healthcare providers participating in federal healthcare programs—including Medicare, Medicaid, and other federally funded services—are advised to verify the OIG Exclusion List prior to extending offers of employment or engaging new vendors. This applies to all potential hires, whether clinical associates, administrative staff, or other personnel, as well as contractors or service providers whose work may be billed to federal programs.
Key Recommendations:
- Pre-Employment and Pre-Engagement Checks: Review the OIG database before offering employment or establishing a business relationship with any individual or vendor.
- Periodic Verification: Conduct regular internal audits to ensure that existing staff and contractors remain clear of the OIG Exclusion List.
- Documentation: Maintain records of all verifications as part of routine compliance monitoring.
Potential Consequences of Non-Compliance:
Hiring or contracting with an excluded individual in connection with federal program services may result in civil monetary penalties or other administrative actions. Regular verification helps protect the practice and supports ongoing compliance efforts.
Reference: OIG Exclusion List: https://oig.hhs.gov/exclusions/exclusions_list.asp