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Hi everybody. This is Dr. Perry Barnhill with the Fearless Chiropractor. Big thanks today for ChiroSecure for having us do this presentation on OIG and what you need to know in regards to the exclusion list. Slideshow please.
Again, big thanks to ChiroSecure for presenting this. Alrighty. Let’s talk about understanding and using the OIG exclusion list, how to perform monthly exclusion lists for your staff and for others as well, which we’ll talk about. Now the OIG is the offices of Specter General. Now what they do is they fall under HHS Health and Human Services.
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It’s not directly related to hipaa, but it is a sister to hipaa. It’s very closely related, and the fact that these organizations and these governmental agencies speak to each other, it’s very important that we understand what the exclusion list is all about. So this is something that we’re gonna actually check each and every month.
What is it and why do we need to check the OIG exclusion list monthly. Now, here’s what it is. Basically, the government, the OIG, the Office of Inspector General has a list. There’s a website to go to, which I’ll share with you. That you need to check each and every month to see if any of your employees or anybody in your office that handles any kind of protected health information to make sure that they are not on this list.
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And what it does is this, it ensures compliance with Medicare. So if you take Medicare, you have to do this Medicaid, and also contract requirements by regularly verifying. Employee eligibility. So you may say, oh, but I don’t take Medicare. I don’t take Medicaid. But you know what? If you’re in insurance with some of the networks, this can apply as well.
So who needs to be checked? Basically anybody in your office really should be checked. Any staff that’s involved with patient care, anybody that’s handling any kind of the billing processes or quite literally, and quite frankly, anybody who has access to the protected health information that we have in our office.
Now, one thing is a side note is that people say you have some cleaners that come in, a janitorial staff or anything like that. They don’t typically require these checks, but always remember as far as HIPAA goes, if you do have people come in the office, they’re separate forms that you should have those people filling out non-disclosure statements just in case they actually de see something.
And that may be a topic for something later, but they do need to be aware that if they see protective health information, they shouldn’t be looking at it or they shouldn’t disclose it. Here we go, step one, the Medicare exclusion list and the website to go to check. It’s right here. What you want to do is literally just go to exclusion.oig.hhs.gov.
This is the website where we’re gonna enter. The information we need to see if a person is on this list. So here’s what you do. It’s real simple. You go in there you jump in there, you don’t have to log in or anything like that, but you enter the employee’s last name and their first name. Now you can use additional details if you have ’em like date of birth.
I mean your employees may or may not have an NPI number. If you have an associate doctor that you hire, then you have to do this with them as well, interpreting the results. So what happens? So if there’s no result. That’s good news. The individual is not currently excluded. However, if you have a match, they very well may be excluded from working for you.
Okay, so here’s what you can do. If you click verify, you can redu review additional details so you can put in additional details for that particular person to make sure that, say it’s a John Doe, and then there’s another John Doe to make sure that the John Doe working for you is not the same person that’s on that list.
All right. And if they’re on that list, guess what? They cannot be in your office. You cannot employ them. If you are accepting any federally funded programs, Medicare, Medicaid, or even if you’re involved with any PPOs or even HMOs, you cannot have them hired. And if you do and they find out, you will get fined.
So here’s another one. Believe it or not, that we need to check, and when I say check these each and every month, you do have to check them each and every month because last month maybe they didn’t commit a crime, they weren’t on the list, but now they are. So you gotta check it. It doesn’t take long. It’s really fast.
But step two, there’s another list. The SAM exclusion list Check. You’re gonna do the same thing. You’re gonna visit this website, sam.gov. You’re gonna search, you’re gonna enter the information in there and you can expla expand the search criteria to include exclusions and then enter your employee’s name to see if they appear.
And of course, if they appear, you’re gonna have to deal with that. Some verification steps. Now, provide as much identifying information as possible. And this is what I was talking about, if they do pop up, make sure it is the actual person that’s in your office. ’cause maybe somebody else out there has the same name.
There’s also a state-based exclusion list. Now I know this is OIG, but this is so closely related to HIPAA that we really need to do these things. Where to check. You’ve gotta go to your specific state portals. All right. Example in HFS Partner portal for Medicaid related sanctions, each state will have different portals to check.
So make sure you go in there and you check for those things. How to search? Very similar. You locate the section for OIG provider solutions and you enter the information in there and make sure that they don’t come up reviewing the information. Again, check the details provided to ensure that it matches the individual.
So make sure you don’t have a person who has the same name as somebody else that may be on the list but is not actually your employee. Also, note any active sanctions or exclusions. Relevant to state Medicaid programs, so make sure you’re checking that as well. It’s not just OIG, but it’s also state. And then on top of that, it’s also any PPOs that you may be part of best practices for verification.
So always verify multiple data points like I was just talking about. Make sure it is in fact the person that’s working in your office and not just a duplicate name. Cross-reference your results. Use the different systems, the OIG, the SAM, and the state-based one to confirm the accuracy. And here’s what you have to do.
Again, if it’s not documented, they think we never did it. So you have to document these things. Keep records. You can make a checklist. We have checklists for this stuff where you just basically write your employee’s name, where you checked it, and that they were or they were not excluded. And obviously if they were excluded, you better make sure you do something about that so you don’t get yourself in trouble.
Importance of regular exclusion lists. I’ll just go over it again. Compliance, so it’s all part of the overall compliance. IT meets Medicare, Medicaid, and certain PPO contracts. Risk management health prevent potential fraud and abuse. If you have someone on there that may have had some issues earlier and they’re working with you.
Who knows, maybe they have arterio motives for working for you and they’re gonna do it again, and you will get in big trouble if you allow that to happen. Quality insurance and includes and ensures that only qualified personnel have access to sensitive patient care and billing information. So important.
So what are the next steps? Again, I’m just gonna recap. We’re gonna go over this again, OIG website. Check for the exclusion list, verify against the SAM exclusion list, check your state, and we record it in our HIPAA manual. You have an OIG manual. If you’re not aware of that, they’re very close related.
You gotta have OIG compliance as well if you’re doing any kind of federally funded program. And again, you have to conduct these checks monthly for all relevant staff. Additional resources. Just to throw up the slide here, you can take a shot of this. I won’t read it out to you, but you can just check it out here.
Download your HIPAA compliance checklist, something that I talk about all the time. If you are not sure if you are HIPAA compliant, you probably are not. If you’re like most of us out there, most of us are not compliant because we just don’t know what it is we’re actually supposed to be doing. So here’s a little cheat sheet.
Here’s a little checklist that you can check. Go through, answer these questions or check them off. If you’re not checking each and every one of these off, it’s likely that you’re not compliant. You can scan the QR code there as well to the right. You can schedule a demo or get started. If you want to, if you wanna schedule a demo of the, of our HIPAA compliance program, just go to go dot fearless provider.com.
You can check out a demo there. If you want to just get started, go to better hipaa blueprint.com or if you want to contact me, I am always more than happy to help any of you. My motto literally is, defend and educate chiropractors so that you don’t get yourselves in trouble. You can reach me at Dr.
Perry at better HIPAA blueprint. Com questions, like I said, reach out to me and in the meantime, everybody have an amazing day.
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