Issue link: https://blog.providence.org/i/1541294
Permissive exclusions based on sanctions by other agencies, such as a state medical board suspending or revoking a medical license, or other misconduct including defaulting on health education loans or providing unnecessary or substandard care. Exclusions are handed down by the OIG and last for periods of typically three to five years in most cases before a potential reinstatement may be made. If you are excluded by OIG from participation in the Federal health care programs, then Medicare, Medicaid, and other Federal health care programs, such as TRICARE and the Veterans Health Administration, will not pay for items or services that you furnish, order, or prescribe. Excluded physicians may not bill directly for treating Medicare and Medicaid patients, nor may their services be billed indirectly through an employer or a group practice. In addition, if you furnish services to a patient on a private-pay basis, no order or prescription that you give to that patient will be reimbursable by any Federal health care program. Some refer to exclusion as a "financial death sentence" for any health care provider. Providence's Exclusion Screening Program & Requirements In accordance with the Medical Staff Excluded Individual Checks policy, Providence prohibits the credentialing and privileging of Medical Staff members and does not do business with those who are deemed by a Federal and/or State agency as debarred, excluded or otherwise ineligible for participation in federal or state funded health care programs, or who have been convicted of a criminal offense related to health care. All Medical Staff members are screened before hiring or contracting and then monthly thereafter against the Office of the Inspector General (OIG)'s List of Excluded Individuals and Entities (LEIE) and the General Services Administration (GSA)/System for Award Management (SAM), OFAC-SDN, CMS Preclusion, Medicare Opt Out, and all State Medicaid exclusion lists to ensure that none of these persons are excluded or become excluded from participation in federal programs. Civil Monetary Penalties Law You should also be aware that OIG may seek civil monetary penalties for a wide variety of abusive conduct, including presenting a claim that is false or fraudulent because it is for a medically unnecessary procedure. OIG also may impose civil monetary penalties for violating the Medicare assignment agreement by overcharging or double billing Medicare beneficiaries. The adjusted civil penalty amounts for 2025 vary depending on the agency and the type of violation. Here are some examples: 1. Department of Justice: The adjusted civil penalties assessed or enforced by components of the Department range from $7,256 to $84,852 for violations occurring after November 2, 2015. 2. Federal Election Commission (FEC): Violations of federal campaign finance law can result in penalties ranging from $7,028 to $82,188. 3. Department of Labor: The 2025 civil money penalty amounts for labor-related violations are specified in a table published in the Federal Register. 4. Executive Office of the President: The inflation- adjusted penalty amount for 2025 is approximately $14,308 when rounded to the nearest dollar. Please note that these amounts apply to specific violations and agencies Giving Gifts to Providence Caregivers Per Providence policy (PSJH-CPP-719 Gifts, Gratuities, and Business Courtesies), directly employed caregivers of Providence are not permitted to accept gifts from independent physicians, even as a thank you or around the holidays. Examples of gifts include: Provider Education Training Manual 30 |