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Compliance Program

Compliance Program

Excluded Persons

The effect of an exclusion (not being able to participate) is:

  • No program payment will be made for any items or services furnished, ordered, or prescribed by an excluded individual or entity under the Medicare (Title XVIII), Medicaid (Title XIX), Maternal and Child Health Services Block Grant (Title V), Block Grants to States for Social Services (Title XX) and State Children's Health Insurance (Title XXI) programs during the period of exclusion.
  • No program payment will be made to any entity in which an excluded individual is serving as an employee, administrator, operator, or in any other capacity, for any services, including administrative and management services furnished, ordered, or prescribed during the period of exclusion.
  • No payment will be made to any business or facility, e.g., a hospital, that submits bills for payment of items or services provided by an excluded party.

As a result, health care organizations must ensure that the HHS-OIG's List of Excluded Individuals and Entities, and the General Services Administration's (GSA's) List of Parties Debarred from Federal Programs have been checked with respect to all employees, medical staff and independent contractors.