List of Excluded Individuals/Entities (LEIE)
What CARF® Accredited Organizations Must Know
The Office of Inspector General (OIG) fights waste fraud and abuse in Medicare, Medicaid and more than 100 other U.S. Department of Health and Human Services (HHS) programs. The OIG maintains a list of excluded individuals/entities (LEIE). The OIG enforces the exclusion program under the authority of the Social Security Act, sections 1128 and 1156. There are two types of exclusions. Mandatory exclusions are those individuals or entities required by law to be excluded from participation in all Federal health care programs. Permissive exclusions are individuals and entities that have been excluded at the discretion of the OIG. There are many felony and misdemeanor offences that may place an individual/entity on the LEIE. Regardless of the offense, organizations that hire an individual/entity that is on the LEIE may be subject to civil monetary penalties.
HHS-OIG may impose civil monetary penalties of up to $10,000 per service claimed while excluded. They may also impose an assessment of up to three times the amount claimed. Excluded individuals extend beyond direct patient care. Providers may not employ, contract with, or arrange for an excluded individual or entity to provide items or services payable in whole or in part, directly or indirectly, by federal programs if such provider knew or should have known of the exclusion. This would include administrators, clerical, volunteers, temporary workers, contractors, etc.
In addition to the Federal OIG list, organizations may need to check their State exclusions list. Although not typically required, it is good practice to check State lists from previous residence of potential personnel.
The CARF® Standards Manual identifies this requirement for all CARF® accredited organizations that receive federal funding, either directly or indirectly. Accreditation Now provides a policy/procedure template designed specifically to address this requirement.
Office of Inspector General Exclusions Program
This content provided by: Accreditation Now, Inc.
