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Fraud & Abuse - December 2003
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Do-It-Yourself Screening for Medicare Approved Providers

Over 33,000 people are currently excluded from Federal healthcare programs. The effect of an exclusion from a Federal health care program is that no Federal health care program payment may be made for any items or services (1) furnished by an excluded provider, or (2) directed or prescribed by an excluded provider.  Civil monetary penalties may be imposed against health care providers or entities that employ or enter into contracts with excluded individuals for the provision of services or items to Federal program beneficiaries. The Office of the Inspector General (OIG) urges health care providers and entities to check the OIG List of Excluded Individuals/Entities prior to hiring or contracting with individuals or entities and to periodically check the OIG web site for determining the participation/exclusion status of current employees and contractors.

Where To Look For Excluded Providers?

Search the following major government databases:

OIG List of Excluded Individuals/Entities (LEIE) contains the names of thousands of persons and businesses that are excluded from participation in federal health care programs.  Go to: www.exclusions.oig.hhs.gov/search.html
OIG Excluded Parties Listing System (EPLS)  contains names of parties excluded by over 50 federal agencies. It is important to check this database because the OIG claims the right to exclude a party from your employment for "fraud/theft/embezzlement/breach of fiduciary responsibility, or other financial misconduct with respect to any act or omission in a program, other than a health care program operated in whole or in part by any Federal, State, or local government agency." Go to: www.epls.gov/servlet/EPLSSearchMain/1
Specially Designated National (SDN) List contains names of suspected terrorists you should not employ.  Go to: www.treas.gov/office/eotffc/ofac/sdn

What Happens When You Find a Match?

If your search finds a match, you must then determine whether the match is really the individual that you are inquiring about or someone else with the same name.  If there is more than one person on the list with the same name, you will have to compare Social Security  numbers, middle names or dates of birth.  If additional information is not available, you can compare dates and locations of verified employment to information from the database.  For example, if your prospective employee Ben Smith worked in Oregon for the previous 5 years, it is safe to conclude that he is not the Ben Smith who was excluded during that period of time for his activities in Ohio.

As a final verification, it is a good idea to check with the appropriate federal agency to find if the exclusion is still in effect.

Document Search Efforts

It is important to document your search efforts.  This documentation may mitigate damages if you hire an excluded individual who did not appear as a match during your search.

Excluded Individuals:

Tips for Successful Searching

Each website allows you to enter in a name and click a button to find if there is a match in the database.  It is important to note that computer matching is very dependent on correct spellings.

Search tips:

Use correct first names, not nicknames (i.e. Benjamin not Ben)
Watch out for initials substituted for first names (use full name) (i.e. William Blake Wilson not W. Blake Wilson)
Pay attention to hyphenated surnames (search for Mary Tyler-Johnson and Mary Tyler Johnson)
Check compound surnames in a similar manner (i.e. search for Mary Tyler Johnson, Mary Tyler and Mary Johnson)
Other known names should also be checked (i.e. maiden names)

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