Kusserow’s Corner: OIG Upgrades Online Searching of the List of Excluded Entities Database

On May 8, 2013, the HHS Office of Inspector General (OIG) issued the “Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs”.  It addressed the scope and frequency of screening employees and contractors against the OIG’s List of Excluded Individuals and Entities (LEIE) to determine if they are excluded from participation in federal health care programs.  In its effort to make the entire process more user-friendly, the OIG announced on July 10, 2013, an update on its efforts to upgrade the LEIE.  Beginning in July, the OIG begins offering monthly supplemental files with new fields; however it strongly recommends that users download the entire LEIE Database with the three new fields at least once during the transition period from June to August 2013. The monthly supplement files only contain information about new exclusions or reinstatements that occurred in a single month.  They do not—and will not—offer national provider identifier (NPI) and Waiver information for the thousands of records already in the LEIE before the latest LEIE upgrade.

The OIG now only archives monthly supplement files for the previous 12 months. Older material is no longer available on the website or via phone call to Exclusions staff, although the Downloadable LEIE gives users the latest information on excluded individuals or entities. The Monthly Supplement files, dated May 2013 or before, will not include the NPI and Waiver fields.

Instructional videos explaining how to use the online database and downloadable files are now available.  The OIG has added NPIs to LEIE records starting in 2008 and will include NPIs in LEIE records on a forward-going basis.  They noted that not every individual or entity that is excluded has an NPI to add. Therefore, many records will not include information in the NPI field.

The OIG also made it clear the LEIE is the primary database for purposes of exclusion screening.

Richard P. Kusserow served as DHHS Inspector General for 11 years.  He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters.  His firm has a number of experienced health care consultants that act as both Designated and Interim Compliance Officers.  The SM sister company, Compliance Resource Center (CRC), provides a wide range of compliance tools, including sanction-screening. 

Connect with Richard Kusserow on Google+ or LinkedIn.

Copyright © 2013 Strategic Management Services, LLC.  Published with permission.