OIG: Hire excluded workers -- even through third parties -- and risk fines

Why This Topic Matters

Providers can face overpayment liability and civil monetary penalties if excluded individuals perform work tied to federal claims, including through third parties. The article helps readers understand the scope of the compliance risk and the importance of vendor oversight and exclusion screening.

Article Sections

1. Compliance

   Introduces the OIG advisory and the general compliance concern involving excluded workers and federal claims.

2. The buck stops with you

   Discusses provider responsibility for excluded individuals associated with billing entities and third-party arrangements, along with broad compliance implications.

3. Exceptions rare, difficult

   Reviews the narrow exception concepts mentioned in the advisory and the challenges of separating excluded personnel from federal program-related work.