Hiring the correct employees is important to any business, but for healthcare companies, compliance with federal law is equally significant.

One important aspect of the hiring process is ensuring that candidates are not listed on the OIG Exclusion List, the consequences of which can be both legally and monetarily costly.

What Is The OIG Exclusion List?

The U.S. Department of Health and Human Services (HHS) maintains the Office of Inspector General (OIG) Exclusion List, a database of individuals and entities excluded from taking part in federal healthcare programs because of fraud, abuse, or other misconduct. Employing a listed individual can have serious repercussions, such as fines and termination of federal funding.

Why Checking The OIG Exclusion List Matters

Not screening employment candidates against the OIG Exclusion List can lead to:

• Legal liability – Companies that employ excluded persons may be liable to pay heavy fines and penalties.
• Financial consequences – When an excluded person provides services paid for by Medicare or Medicaid, the organization may have to repay all the related claims.
• Reputational harm – The reputation and credibility of your business may be lost as a result of non-adherence.

How To Screen Applicants Against The OIG Exclusion List

In order to be compliant, employers must integrate the following best practices:

1. Perform pre-employment OIG screening

Employers are required to check the OIG’s List of Excluded Individuals/Entities (LEIE) before hiring any applicant to ensure that they are not excluded. The database can be found on the HHS OIG website and is updated on a monthly basis.

2. Perform continuous employee screening

Verification of the OIG Exclusion List is not a one-time activity only. Conduct periodic screening to help ensure current employees are in good standing and are not subsequently added to the exclusion list.

3. Utilize automated screening tools

Manual searches are error-prone and time-consuming. Most organizations utilize automated screening software to incorporate OIG exclusion screening into HR and hiring processes.

4. Keep proper records

Employers must record all exclusion screenings and maintain a record of the results. This assists with proving compliance if there is an audit.

5. Take action if an employee is found on the list

If the employee is found on the OIG Exclusion List, immediate action is necessary, including termination of employment or consultation with counsel about potential remedial actions.

Conclusion

Hiring top employees means more than assessing skills and experience; it also requires due diligence when it comes to adherence to laws. Screening applicants against the OIG Exclusion List protects your organization from legal action, financial penalties, and damage to your organization’s image. By conducting thorough pre-employment screening and ongoing monitoring, organizations can ensure they remain compliant and maintain workforce integrity.