An Illinois-based home health agency will pay $35,597.37 to settle allegations it employed an individual who was excluded from participating in any federal health care programs, according to the HHS Office of Inspector General.
OIG had alleged that the excluded individual, who worked as a nurse and case manager, provided services that were billed to federal health care programs. The exclusion list is updated monthly, and agencies have to routinely check the list to avoid an issue, experts warn.
Some expert tips from the HHL archive:
- Make multiple checks. While it’s a no brainer to check the list when hiring new employees, it’s important to check the list against their names monthly, especially in the month immediately following hire. It is possible for a candidate to not be excluded at the time of hiring, but then become excluded later. This can occur if the exclusion process is initiated after the individual was hired, or the process of adding them to the list was not completed at the time of hire. The exclusion list is updated monthly.
- Don’t make exceptions. When the hiring managers hire someone they are familiar with, they may skip checking the list because they don’t believe that person could be excluded or suspended. It’s important that every single person is checked against the list, regardless of your relationship with them.
- Ask candidates for all aliases. Sometimes people have multiple aliases that they are known by or have changed their name at some point. Agencies should require candidates to provide all names they have been known by, then check each name against the list.
- Don’t use staffing shortages as an excuse. While agencies might be desperate to fill the organizational chart, hiring excluded individuals only provides a short-term gain.