Employing or contracting with even one excluded individual, an employee, a contractor, a vendor, exposes your organization to civil monetary penalties and repayment of every claim touched by that person. A lack of knowledge is no defense: the government expects you to know the exclusion status of everyone you employ or do business with, and both OIG and CMS contractors are actively hunting for violations. For third-party billing companies and physician practices, exclusion screening is not a box-checking exercise; it is one of the highest-stakes obligations in your entire compliance program.
Yet most organizations are still getting the fundamentals wrong: screening annually when monthly checks are expected, checking only the OIG LEIE while ignoring state Medicaid exclusion lists and the GSA-SAM database, screening employees but not vendors and contractors, and failing to document their efforts in a form that will survive an audit. Each of those gaps is a finding waiting to be written up, and a penalty waiting to be assessed.
In this 60-minute session, two former DOJ prosecutors, Robert W. Liles explain exactly what your screening obligations are under federal and state regulations, which databases must be checked and how often, who must be screened, how to document compliance, and how the CMS Preclusion List differs from the OIG Exclusion List and reshapes your employment and contracting practices. If your organization cannot produce documented proof of monthly screening today, this session is not optional.
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