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What causes exclusion?

Exclusion can be caused by convictions for healthcare program-related fraud and abuse, including patient abuse, as well as felony convictions for controlled substances. The Office of Inspector General (OIG) of the Department of Health & Human Services has the authority to exclude individuals and entities. For a list of mandatory and permissive exclusions, please see [...]

By |2017-05-17T18:31:19+00:00May 17th, 2017||0 Comments

I have received a letter in the mail, and I don’t understand what to do.

The letter means that you are a Vendor organization that provides services to health care providers or other organizations that receive federal/state medical assistance funding (e.g., Medicaid). Federal and state regulations require healthcare providers to notify you of your requirement to conduct sanction screening to determine if your entity and any of your employees are [...]

By |2017-05-17T18:30:29+00:00May 17th, 2017||0 Comments

Please describe your capabilities with respect to screening for the types of individuals and entities that health care institutions are required to check (employees, contractors, volunteers, physicians, and vendors).

OIG Compliance NOW provides comprehensive screening service for all types of individuals and entities, including employees, physicians, referring physicians, volunteers, and vendors/contractors (entity names as well as employees). We would support health care institutions in providing all individuals and entities with a clear and conspicuous disclosure, in writing, that the OIG Sanction Report will be [...]

By |2017-05-10T19:05:25+00:00May 9th, 2017||0 Comments

What details are provided in your reports (i.e., matches only, explanation of sanctions associated with a match, etc.)?

Any client with validated exclusions will first be contacted by telephone prior to the generation of the monthly report. When an association match is found, an OIG Compliance NOW investigator takes that record and verifies that the employee or vendor is sanctioned and/or excluded. After all of the association matches have been investigated and verified, [...]

By |2017-05-10T19:05:47+00:00May 9th, 2017||0 Comments

Please describe additional resources or capabilities that you offer (if any) to your clients to help them stay abreast of new requirements, changing regulations, etc., on this subject at both the Federal and state levels.

We are prepared to offer clients a comprehensive compliance solution for sanction screening which includes a sanction screening checklist, quarterly updates of new requirements/regulations, and an annual review of the program to encourage the development of a long-term, “best practice” compliance program. We stay connected to various federal, state and professional organizations to stay alerted [...]

By |2017-05-10T19:05:52+00:00May 9th, 2017||0 Comments

What is your mechanism (if any) for ensuring that an individual or entity who shows up as excluded on one of your reports, but is cleared by the health care institution, does not show up on subsequent reports?

Our standard procedure is to report all active exclusions that appear in our monthly search results. However, using our unique and proprietary OIG Investigations tracking system, we are able to automatically identify individuals that were investigated in previous months and list those individuals as “previously identified and reported to client”. In terms of “clearing” excluded [...]

By |2017-05-10T19:06:02+00:00May 9th, 2017||0 Comments

If there is a match on an individual list (including state lists), what assistance can your company provide to help the health care institution to acquire the information needed to verify the match?

Part of our validation process includes obtaining documentation from local, state and federal agencies regarding the nature of the exclusion. We then share this documentation with the health care institution as part of our master validation report.

By |2017-05-10T19:06:07+00:00May 9th, 2017||0 Comments

If and how you confirm the identity of an excluded individual or entity in order to distinguish between an excluded individual or entity and others with the same or similar names, etc.

Results are ALWAYS VALIDATED before any communication back to the health care institution. Names of excluded individuals and entities are confirmed to be accurate through a manual investigative process that involves verbal communication with local, state and federal agencies, as required.

By |2017-05-10T19:06:11+00:00May 9th, 2017||0 Comments
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