This document outlines 7 ways to ensure a healthcare organization is not compliant with OIG exclusion list monitoring requirements. It notes that relying solely on the LEIE is insufficient as it is missing many exclusion records. It also emphasizes the need to monitor vendors, contractors and physicians in addition to employees. Checking exclusion lists only on the federal level and not also on state lists is non-compliant. The document recommends checking exclusion lists at minimum on a monthly basis, using a system to archive monitoring results, checking for exclusions before hiring anyone, and using an automated instead of manual system to reduce errors and time spent. It promotes the services of ProviderTrust to help organizations effectively meet OIG compliance standards.

1. 7 Ways to Ensure You are
ABSOLUTELY NOT
OIG Compliant.
(You’re welcome.)

2. 1. Rely on the LEIE.
The LEIE is NOT a complete list. Not even close.
In 2008, the OIG audits the LEIE, and what do they find?
Up to 61% of state excluded providers failed to show up timely or at
all on the OIG LEIE.
LEIE is only 21% of exclusion records.
How are you monitoring the other 79%?
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

3. 2. Only checking your Employees.
In addition to your employees, you need to be actively
monitoring vendors, contractors, physicians, and even
referring physicians.
Many organizations have more vendors than employees.
Leaving that group out of your monthly monitoring leaves
out a HUGE percentage (and leaves you liable for fines!)
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

4. 3. Ignore the Individual State Lists.
ObamaCare = excluded in one state, now excluded in all states
An Even BIGGER Impact of ObamaCare?
“Moving the industry from recommended to mandated
compliance programs.” -- Alice Martin, Esq.
Bottom Line: Start Checking the State Lists. Today.
(Remember: Your organization is responsible for self-disclosing ANY excluded providers.)
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

5. 4. Don’t check lists at least
every month.
“Our practice is to update the list monthly...”
“I don’t think it would be a bad idea to check the LEIE monthly.”
-- HHS Inspector General Daniel Levinson
Listen to the General. Check em.
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

6. 5. Don’t use a system to archive
your monitoring.
Q: Checking the lists is extremely time-consuming,
state lists are remarkably difficult to check, and
where and how do you archive what you find?
A: Make your life easier and implement a monitoring system.
You’ll thank us later.
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

7. 6. Don’t check for exclusions
before you hire.
“Bad Nurses Able To Keep
Working In Different States”
-- USA Today, 2010
“Nurse Krystal Bauer... moved so fast she amassed allegations in
multiple states before her home state caught up.”
Know who you’re hiring BEFORE you hire.
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

8. 7. Checking everything.......manually.
Let’s face it - checking everything consistently can be a nightmare.
It can be incredibly time-consuming and frustrating.
Not to mention, if you miss something you could be liable for
huge penalties.
Make your life a lot easier - implement an automated monitoring
system that checks everything in real-time.
7 Ways to Ensure You are ABSOLUTELY NOT OIG Compliant.

9. Staying OIG Compliant is hard.
We get that. And we’re here to help.
ProviderTrust brings you real-time compliance in an easy and
simple way, providing ongoing monitoring with matched results.
Give us a shout to learn more about compliance and
monitoring solutions. You’ll see why we love doing
what we do. Looking forward to meeting you!
Chris Redhage
credhage@providertrust.com
615.938.7878