I need advice urgently! We have discovered today that a coding contractor, who we have had for 6 months, is on the OIG Excluded List. We performed an exclusion check yesterday during an audit and the contractor's name came up. Two months ago, the contractor was placed on the OIG Excluded List for a previous incident at another facility. What are our potential liability risks? We have already billed Medicare for services the contractor provided. Should we self-disclose or consult with a lawyer before self-disclosing? I am feeling extremely stressed.

Discussing what it means to have an OIG exclusion. An OIG exclusion prohibits a person from participating in any federal healthcare program and includes all aspects of healthcare (i.e., performing patient care directly. performing a direct service through administration or management, etc.) Furthermore, it is important for those working in healthcare or related areas to understand the full extent of an OIG exclusion, as it means that an individual cannot work for, receive funds from, or provide services to any federally supported entity.

Hi everyone! I have a quick compliance question. We are required to run monthly background and sanction checks on all doctors and nurses in our clinic. Are we also required to check outside vendors? We have hired a company to do our clinic's IT support and light cleaning. Should we do the same checks on their staff? I want to make sure that our clinic does not incur huge fines due to non-compliance. What procedures do you have in place to handle contractors?

Hi! We have several pharmaceutical representatives that come in periodically to drop-off lunches for our medical staff. I realize that drug companies are supposed to have these expenses tracked in the Open Payments CMS program. As the practice manager, do I need to maintain my own separate record of these lunches, or are records kept for all drug company lunches? I just want to make sure that our doctors do not have a surprise later when the numbers reported might be incorrect. What does everyone else do?

This year has anyone else experienced the dispute resolution process in Open Payments CMS portal as being troublesome? We are developing our information about payments transfers of value to physicians and therefore want to reduce errors prior to submission deadline to minimize the need for long back and forth corrections. I would be interested to know what methods your organization uses for pre-submission review. Do you provide the physician with this data for review prior to submitting or uploading it into the CMS?