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April 20, 2014

Department of Health and Human Services Office of Inspector General Releases Updated Special Advisory Bulletin on Exclusions from Participation in Federal Health Care Programs

Fourteen years after the original bulletin, the Department of Health and Human Services Office of Inspector General (OIG) released an updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs.

The Bulletin details the consequences of exclusion from  federal health care programs and provides guidance for employers. Since the release of the 1999 bulletin, the OIG has received several questions about exclusions, many of which they address in the 2013 update.

The updated Bulletin:

(1). Confirms guidance from the 1999  bulletin on the scope and effect of an OIG exclusion;

(2). Provides additional guidance on the scope of the payment prohibition and potential Civil Monetary Penalty liability;

(3). Provides guidance on best practices for screening against the List of Excluded Individuals and Entities to ensure that providers do not employ or contract with an excluded individual; and

(4). Directs providers to use OIG’s Self-Disclosure Protocol to self-disclose the employment of, or contract with, an excluded person.

A notice announcing the bulletin will be included in the May 9 Federal Register publication.

© 2014 BARNES & THORNBURG LLP

About the Author

Nita Garg, Health Care Attorney, Barnes Thornburg, Law firm
Staff Attorney

Nita Garg is an associate in Barnes & Thornburg LLP’s Chicago office and a member of the firm’s Healthcare Department. Ms. Garg assists clients with healthcare issues, including physician employment, physician-hospital contracting, Medicare and Medicaid reimbursement, and various state and federal regulatory matters, including fraud and abuse and HIPAA. 

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