If you participate with Medicare/Medicare Advantage/Medicaid programs, you must have a written Fraud, Waste and Abuse Prevention Program. One of the important elements of such a program is checking the Office of Inspector General (OIG) exclusions list. The OIG is the regulatory body that provides enforcement when fraud, waste and abuse is identified within the Medicare/Medicaid programs.
Exclusion checks should be performed prior to hire for potential candidates, and at intervals for existing staff, depending on the percentage of your overall revenue that is made up of Medicare/Medicaid claims. You can find the OIG exclusions search page here: https://oig.hhs.gov/exclusions/index.asp From this page, you are able to navigate to the exclusions search page, or the LEIE download page. The OIG has issued the following tips for searches.
• Because the Online Searchable Database and the Downloadable Database include only the name known to OIG at the time the individual was excluded, any former names used by the individual (e.g., maiden name, previous married name, etc.) should be searched in addition to the individual’s current name.
• In order to achieve the most accurate search results, enter only the first few letters of the first and last names.
• An individual with a hyphenated name should be checked under each of the last names in the hyphenated name (e.g., Jane Smith-Jones should be checked under Jane Smith and Jane Jones, in addition to Jane Smith-Jones).
• Maintain documentation of the initial name search performed and any additional searches conducted to verify results of potential name matches.
• If checking only a few names, use the Online Searchable Database to search up to five names at once.
• If checking many names, consider downloading the Downloadable Database into a spreadsheet or database program. This will enable the user to use that program’s search functions to crosscheck the names against the thousands of names on the LEIE. Verify the correct spelling of any names before starting a search.
• Always remember to take the final step of identity verification using the Social Security Number (SSN) for an individual or Employer Identification Number (EIN) for an entity. It is not sufficient to simply find a matching name on the LEIE.
• For a potential match using the Downloadable Database, verify the results by entering the SSN for an individual or EIN for an entity on the Online Searchable Database. (Note: The Privacy Act prohibits the distribution of SSNs so they cannot be included in the Downloadable Database).
• If a search result does not contain a DOB, UPIN, NPI, EIN, or SSN, it is not available from OIG. You should contact the Exclusions Branch at https://oig.hhs.gov/aboutoig/contact-us/#exclusions to determine if there is any other information available.
