Kusserow on Compliance: OIG updates the LEIE

Many may have not noticed that the HHS Office of Inspector General (OIG) continues to upgrade their List of Excluded Individuals and Entities (LEIE) system to make it more user-friendly. Anyone who has sanctioned-screened against the LEIE and the General Services Administration (GSA) Excluded Party Listing System knows how unfriendly the GSA system can be to users. The most recent upgrading by the OIG has been to link their sanctioned individuals and entities to the National Provider Identifier (NPI) records, which are part of the CMS National Plan and Provider Enumeration System (NPPES). The result of this upgrade is an improved system, which makes it much easier to determine whether a potential hit is actually identifiable to an individual.

Before the implementation of the upgrade, it was possible to miss a confirmed hit because the name screened may have been incorrect in some manner. This could happen even if a user searched by name through the NPI registry. This has occurred many times, leaving an entity to believe all their practitioners were clear of the LEIE, only to learn later that was not the case. Now that this new feature is included in the LEIE, the chances of missing a hit because of a flawed name entry have been all but eliminated. This also underscores the importance of following a proper resolution process. Failing to do so may create potential penalties.

The National Provider Identifier (NPI) is a Health Insurance Portability and Accountability Act (HIPAA) (P.L. 104-191) Administrative Simplification Standard and is a unique identification number for covered health care providers. Covered health care providers and all health plans and health care clearinghouses must use the NPIs in the administrative and financial transactions adopted under HIPAA. The NPI is a 10-position, intelligence-free numeric identifier. This means that the numbers do not carry other information about health care providers, such as the state in which they live or their medical specialty. CMS updates the NPI files weekly to provide users with more up-to-date information, which includes newly assigned NPIs, updates to NPI data, and newly deactivated NPIs covering that week. This weekly incremental NPI file is a supplemental file designed to be used in conjunction with the full replacement monthly NPI file until the next full replacement monthly NPI file is made available.

Tips

  • Be sure to have the NPI for any provider being screened against the LEIE.
  • Take steps to ensure that the names being searched are complete and reflect the information in the credentialing process.
  • For more information on how to properly screen and resolve potential hits, visit the Compliance Resource Center.

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. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

Copyright © 2016 Strategic Management Services, LLC. Published with permission.