If your healthcare organization relies on Medicare and other federal benefits, your worst fear may be ending up on the system for award management exclusion list. A non-compliance incident on your record can bar you from federal funds that enable you to provide essential medical care. Also, hiring an employee or vendor who appears on the exclusion list can open your entity to criminal penalties.
Learn what the system for award management exclusion list is, how you can access the System for Awards Management to check your exclusion status, and how compliance software can help.
What Are Award Exclusions?
OIG has the authority to exclude individuals and entities from Federally funded health care programs for a variety of reasons, including a conviction for Medicare or Medicaid fraud. Those that are excluded can receive no payment from Federal health care programs for any items or services they furnish, order, or prescribe.
The Office of Inspector General enforces two types of exclusions. One is the mandatory exclusion, which applies to criminal activities like patient abuse or neglect, fraud or theft, bribery, and any felony related to controlled substances, such as dispensing, manufacture, or possession.
There are also permissible exclusions, including:
- Excessive or unnecessary charges for medical services
- Failure to perform services that meet regulatory standards
- Receiving kickbacks for referred services
- Obstructing an investigation or audit
- Failing to take the required corrective actions after an audit or investigation
- Misdemeanor convictions related to controlled substances
- Making false statements or misrepresenting facts
- Employing providers who practice without proper licenses or certifications
- Defaulting on educational loans or scholarship obligations
- An entity having ownership or management by an excluded individual
Regularly checking the system for award management exclusion list is essential to avoid serious consequences. Even unknowingly hiring someone on the exclusion list can render your entity ineligible for Medical or Medicare, leaving you open to fines and other legal penalties.
What Is the System for Award Management Exclusion List?
The System for Award Management (SAM) is a free online service of the U.S. General Services Administration. It combines all federal awards into one system, allowing you to learn about available grants and obtain procurement information. SAM also allows you to search for individuals and entities on the awards exclusions list.
Unfortunately, many individuals and organizations don’t know they’re on the list. That’s why checking the system for the award management exclusion list should be regularly scheduled.
What If an Employee or Vendor Is on the System for Award Management Exclusion List?
If you check the watch list system for award management exclusions and discover that an employee or vendor is on the list, you must immediately act. First, suspend their work while you verify their exclusion status. Double-check the record to ensure it’s up-to-date and determine the reason for the exclusion. Assuming the exclusion status is correct, suspending or terminating the employee or contract may be necessary.
Notify your organization’s legal department and compliance program team immediately so they can advise you on the next steps. One such action would be to remove the excluded entity from any Medicare, Medicaid, or other federal program in which they’re involved. Also, ensure your organization isn’t submitting any claims on which the excluded person or party has worked.
Your compliance officer will need to contact federal authorities if necessary. They’ll likely begin an investigation to determine the reason for the exclusion and assess any potential outcomes, such as fines or other penalties. The organization will need to take corrective actions to improve compliance efforts, such as improving screening and background checks of future vendors and employees.
Accessing the Watch List System for Award Management Exclusions
You can access the system award management exclusion list for free at SAM.gov, which holds all the records for an entity in one place. You can narrow your search by exclusion classification (e.g., individual, entity), federal organization, location, and other parameters. While you don’t need to set up an account to view the list, you must register your entity if you enter federal contracts or receive benefits from federal programs.
Even with a free website to help you regularly check the exclusions list, monitoring the system can get lost in the shuffle of many other compliance activities. With a software package from Compliancy Group, you can automate administrative tasks, ensure your personnel get the necessary compliance training, and effortlessly produce documents and reports your members can access quickly.
Knowing your status regarding the system for award management exclusion list is crucial for keeping your organization in good standing. Contact Compliancy Group today for more information on our software and other resources that can support your compliance efforts.
