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Excluded Parties – OIG Bulletin On Reimbursement

Wednesday, May 15th, 2013

OIG Bulletin On Reimbursement For Services of Excluded Parties

excluded party reimbursementThe Office of Inspector General has issued an updated Special Advisory Bulletin that describes the scope and effect of the legal prohibition on payment for services that are provided by excluded parties. The Advisory Bulletin was issued on May 9, 2013.

The updated Bulletin provides guidance to the health care industry on the scope and frequency of screening employees and contractors to determine whether they are excluded persons.

In the Bulletin, the OIG clarifies that services that are furnished by an excluded person or under the medical direction or prescription of an excluded person do not qualify for reimbursement under Federal health care programs.

Payment by a Federal health care program can include amounts based on a cost report, fee schedule, prospective payment system, capitated rate, or other payment methodology.

The OIG Bulletin describes how the exclusion prohibition can be violated and the administrative sanctions OIG can seek.

See: Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs; Special Advisory Bulletin dated May 9, 2013

John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

Tel 715.845.4336
Fax 715.845.2718

Ruder Ware is a member of Meritas Law Firms Worldwide

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