AI Enabled Watchlist Insight for OIG

Nikit Lodhi
Nikit Lodhi Member, Staff Posts: 1

What is an OIG check?

An “OIG check” is the process of ascertaining whether a particular individual or entity is found on the HHS Office of Inspector General’s List of Excluded Individual/Entities (LEIE). Excluded individuals are prohibited from receiving reimbursement, either directly or indirectly, from any federally-funded health care program such as Medicare, Medicaid or SCHIP.

What is the List of Excluded Individuals/Entities (LEIE)?

The Office of the Inspector General’s (OIG) List of Excluded Individuals/Entities (LEIE) provides information to the health care industry, patients and the public regarding individuals and entities currently excluded from participation in Medicare, Medicaid and all other Federal health care programs. The OIG imposes exclusions under the authority of sections 1128 and 1156 of the Social Security Act which outline conditions and timeframes for exclusion. Individuals and entities who have been reinstated are removed from the LEIE

What happens if a health care provider contracts with an excluded individual for services?

If a health care provider arranges or contracts (by employment or otherwise) with a person that the provider knows or should know is excluded by OIG, the provider may be subject to CMP liability if the excluded person provides services payable, directly or indirectly, by a Federal health care program. OIG may impose CMPs of up to $10,000 for each item or service furnished by the excluded person for which Federal program payment is sought, as well as an assessment of up to three times the amount claimed, and program exclusion.

How Often Should Exclusion Checks Be Done?

While there is no statutory or regulatory requirement to check the LEIE, the OIG recommends that providers screen their employees, contractors and volunteers for exclusion prior to employment or engagement and on a monthly basis to minimize risk.

How can Infor GRC help with this requirement?

We have a AI Enabled Watchlist Insight that allows you to look up entities and monitor them against the list. In GRC, you have a friendly user interface to filter the data and focus on actual violated entities and perform mitigation steps.