Thus, making it possible that one can have a sanction on the state level, but not show up on a federal list. Delays or lags of time of many months between when an individual is sanctioned on the state level to when that offense is actually reported on the federal level.Here are just a few examples of what could happen within your healthcare data and employee population when a sanction occurs but would be hard to detect.
A person or entity can be excluded by a federal agency (HHS OIG) or by a state Medicaid agency.Ĥ0% of the time, excluded providers on the OIG’s List of Excluded Individuals and Entities are derived from their license being sanctioned or revoked.Ī manual sanction screening process can leave HR and Compliance teams left with what seems to be an insurmountable task of constant monitoring and updating their information. Under the Affordable Care Act, an individual or entity/vendor excluded in one state is not permitted to participate in federal healthcare funds in all other states. Once an individual or entity is excluded in one state, he/she/it is considered excluded in all states ( Section 6501 Affordable Care Act). Additionally, the exclusion can also lead to GSA SAM.gov debarment and/or a state(s) exclusion, too.
Once added to the OIG’s LEIE (List of Excluded Individuals and Entities), these individuals or entities are prohibited from participation in federal or state healthcare programs and cannot receive federally funded reimbursement from programs like the Centers for Medicare and Medicaid Services (CMS). This process can take months and even years to progress.Ī sanction from a healthcare disciplinary or licensing board can have significant consequences. Upon the issuance of a penalty, sanction, or disciplinary action, an individual’s license may be restricted, revoked, suspended, or other measures placed upon it. Thus, the individual has an opportunity to present his/her case. Prior to a healthcare professional receiving a sanction, there has been a due process hearing at the license or disciplinary board and/or the excluding agency. Exclusions are typically reserved for those who pose a high risk to patients or a program’s integrity.
Sanctions can be imposed for many reasons but are primarily the result of patient abuse, criminal convictions related to diversion of controlled substances, or healthcare fraud.Īn exclusion, however, is the result of an extreme sanction which is issued by the HHS OIG (Office of Inspector General). Because the HHS OIG and SAM.gov federal databases refer to exclusions as “sanctions”, there is often confusion amongst healthcare and compliance professionals and the two terms are incorrectly used interchangeably.Ī sanction (also referred to as a medical sanction) is the result of a disciplinary action taken against an individual’s license by a state administrative board- commonly by a state licensing board.
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