Recent OIG Enforcement Actions Involving Excluded Individuals and Entities

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The Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services has the authority to exclude individuals and entities from Federal health care programs.  The OIG maintains a List of Excluded Individuals and Entities (“LEIE”) on its website which is updated on a regular basis. Please click here to access the list.

Any health care provider or supplier should query the LEIE before employing any individual, or alternatively, before contracting with any individual or entity,  so to ensure that the party is not listed in the LEIE.  During the course of these employment and contractual relationships, the provider or supplier should also take the steps necessary to update these LEIE queries on a regular basis in accordance with applicable requirements.  To do otherwise, leaves the provider or supplier at risk of an OIG enforcement action that could result in civil money penalties. 
We would like to bring to your attention three 2014 cases that were published on the OIG website which illustrate the importance of these requirements. Please click here for more information.
The first case involved a chain of senior living communities which settled a case with the OIG for $353,248.82 for allegedly employing two excluded individuals.   The second case involved a university-based health care system including four hospitals and 10 neighborhood health care centers which entered into a settlement agreement for $197,839.94 with the OIG, again for allegedly employing three excluded individuals.  The third case, involved a not-for-profit faith-based long-term-care organization which entered into a settlement agreement for $30,121.82 with the OIG for allegedly employing a single excluded individual. 
If you have questions regarding these enforcement actions, the OIG requirements, or the  adequacy of your current policies and procedures to address these requirements, please contact Susan Ziel at