They Should Have Known!
While searching the internet in an unrelated issue, I stumbled upon the OIG page related to fraud and abuse in health care where false and fraudulent claims are listed. Below is what was reported regarding an organization called Shopko Stores in Utah. Notice that the OIG imposed a monetary penalty greater than a half a million dollars for employing someone that the organization ‘knew or should have known’ was excluded from the Medicare program. From the Office of Inspector General’s Fraud and Fraudulent Claim web page which can be found here.
After it self-disclosed conduct to the OIG, ShopKo Stores, Inc. (ShopKo), Utah, agreed to pay $669,824.74 for allegedly violating the Civil Monetary Penalties Law. The OIG alleged that ShopKo employed an individual that ShopKo knew or should have known was excluded from participation in Federal health care programs.
Since Medicare Providers are held to the standard of ‘what should be known’ in addition to what they actually know, reasonable diligence is expected. The surest way to protect your agency is to develop a comprehensive corporate compliance program. At the very least, agencies should check all employees and referral sources against the OIG exclusion database which can be found by accessing this link.
Haydel Consulting Services cheerfully assists agencies in developing their own corporate compliance plan. We are certainly less expensive than OIG imposed civil monetary penalties. Please feel free to contact us at 225-253-4876 or firstname.lastname@example.org.