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With CMPs for Employing Excluded Individuals on the Rise, Providers Should Review Their Exclusion Check Policies

Over the past three months the Office of Inspector General of the U.S. Department of Health and Human Services (“OIG”) has imposed civil monetary penalties (“CMP”) on 13 health care providers who employed individuals excluded from participating in Medicare and Medicaid. Most of these CMPs (10) were imposed on health care providers who self-reported the issue to the OIG, which likely explains the rise in these types of matters. The CMPs ranged from $10,000 imposed against a surgery center to $1.9 million levied against a diagnostic laboratory and imaging company.

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