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 individuals and allowing them to work within the Medicaid system, regulations do state that an exclusion can be overcome when OIG finds that significant factors weigh against exclusion. In the case where a health care institution client feels that a sanctioned individual or entity can be “cleared” to work, OIG Compliance NOW will contact OIG to discuss the factors in greater detail, which will involve: circumstances of the misconduct and seriousness of the offense; the individual’s role in the case of a sanctioned entity; the individual’s actions in response to the misconduct; and other information about the entity. It may be permissible for the health care institution to apply for a waiver for the excluded individual.