The Office of Inspector General (OIG) maintains the List of Excluded Individuals and Entities (LEIE) as a useful tool that helps safeguard federal healthcare programs from both fraud and abuse. Additionally, the LEIE enhances and ensures high-quality care and protects the public’s health. Healthcare organizations and entities receiving federal funding must understand OIG LEIE and the implications of having vendors or employees on this exclusion list.
The LEIE regulates hiring processes and helps maintain compliance with federal hiring regulations, so it’s important to know how to check the exclusion list, what to do if you notice a name appears on it, and how this list can affect your business.
Understanding the OIG Exclusion List
The LEIE provides a complete list of any entity or individual excluded from participating in programs such as Medicare and Medicaid, as well as other federal healthcare programs. This list is updated monthly, and those that have been reinstated since appearing on the list won’t be included in the updated monthly file.
This means that they will not appear as previously excluded even if you start to work with them three weeks after being officially reinstated. However, you can still determine if they were previously on the list by searching the Exclusions Database, which can be found on the OIG website.
Let’s take a look into what it means to be on the OIG LEIE and why it matters for compliance and risk management.
The Criteria for Inclusion on the OIG LEIE
Getting on the Office of Inspector General’s list of Excluded Individuals Entities LEIE can happen for multiple reasons:
- Committing a form of fraud
- Abusing a patient
- Felony convictions
- Failing to comply with the Social Security Act
- Controlled substance violations
The length of time spent on the LEIE depends on the offense. However, there are minimum periods based on the number of offenses of an individual. For example, a first-time offense will require exclusion for a minimum of five years, while a third offense will result in permanent exclusion from participating in federal healthcare programs.
To be removed from the LEIE (if applicable, depending on the number of prior offenses), individuals would have to apply for reinstatement and await their written notice if the OIG grants the request for reinstatement.
Types of Exclusions: Mandatory vs. Permissive
There are two types of exclusions: mandatory and permissive. Mandatory exclusions are for more serious offenses, while permissive exclusions give the OIG some wiggle room to exclude individuals or entities based on discretion, which will often last one to three years.
Permissive, conviction of a misdemeanor crime:
- Forms of fraud connected to using government programs
- Defaulting on scholarship or loan obligations
Mandatory, conviction of a felony crime
- Medicare or Medicaid fraud
- Patient abuse or neglect
How to Approach Checking the OIG Exclusion List
There are a few ways that healthcare organizations can approach checking the LEIE.
Online Search Tools and Databases
Companies can locate the OIG LEIE Exclusions Database at any time and simply perform a search as long as they know the first and last name of the person they want to search. If you are searching for the Office of Inspector General’s list of Excluded Individuals Entities LEIE, you would need the name of the organization. It is likely that you will find multiple results depending on how common the name is, so you should have either the Social Security number or employer identification number to verify your search results.
Contacting the Exclusions Branch Directly
Contacting the exclusions branch can help if you have limited information to support your search for the Office of Inspector General LEIE status or if information is excluded from your results, such as a DOB or NPI.
Cross-Referencing With Other Lists
Cross-referencing your search with other lists will complement your OIG LEIE search. Businesses can use other lists, such as the Federal SAM.gov database or even CMS Medicare lists.
Frequency of Monitoring
Monitoring the OIG Exclusion List should be done regularly, and if needed, you can check the entire OIG LEIE Exclusions Database to assess the Office of Inspector General LEIE status. Considering that this list is updated monthly, if you are continuously working with third-party vendors, you should perform a monthly check as part of your workflow.
Enhancing the Way You Use the OIG LEIE
The best way for healthcare organizations to enhance their compliance and risk management strategies is to implement comprehensive compliance programs, regularly check the OIG LEIE database, and use software that gives them the accessibility to cross-reference other lists within their search.
