Exclusion Lists [Healthcare Compliance Tips]

Review and implement checking exclusion lists regularly within your practice.

In Part V of our series called “The Comeback Story: 9 Compliance Resources to Level Up Your Practice,” you must assign someone to check the:

LEIE, GSA, SAM and State Exclusion Lists

Purpose:

The exclusion lists provide information for the healthcare industry, patients, and the public, regarding individuals and organizations excluded from participating in Federal healthcare programs (e.g. Medicare, Medicaid, TRICARE).

The name of the databases includes:

• List of Excluded Individuals/Entities (LEIE)
• General Services Administration (GSA)
• System for Award Management (SAM)
• All state exclusion lists

How to Use It:

I have seen articles and received OIG alerts in which healthcare organizations owe large sums of money due to them not checking their staff, consultants, vendors, IT support services, volunteers, etc., against the list. It is even getting to the point that they are suggesting that anyone connected to a practice should be checked (e.g., cleaning services, referrals).

The database can be searched by individuals, singles, or multiple entities. If you are caught with an excluded individual from any state, you may run the risk of becoming an excluded entity, or subject yourself to civil monetary penalties.

Therefore, it is suggested that you ensure everyone is qualified to work within the practice at a federal and state level by checking the database on a consistent basis.

**The opinions and observations from the group/author are not a promise to exempt your practice from fines and penalties.  Research, modify and tailor the advice to fit your specialty

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