decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Investigation Procedures / Administrative, Civil and Criminal Sanctions / Exclusion of Providers From Medicare and Medicaid / Joint Development of Actions
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Article Overview
This article covers a specific OIG enforcement procedure involving the joint development of exclusion actions and civil money penalty actions in Medicare and Medicaid-related provider cases. It is aimed at compliance, auditing, and health care legal audiences who need to understand how federal and state health care convictions can lead to parallel administrative enforcement activity. The discussion focuses on the general workflow used by OIG field offices, the circumstances under which a penalty case may be pursued alongside exclusion, and the role of exclusion length in that process.
Why This Topic Matters
Understanding this enforcement coordination is important for organizations and practitioners tracking provider sanctions, Medicare participation risk, and government recovery strategies. The article helps readers recognize when a single case may trigger more than one type of OIG action.
What You Will Learn
- How OIG may coordinate exclusion and civil money penalty development in a provider case
- What general factors prompt a field office review for possible parallel action
- Why exclusion length can become part of the enforcement discussion in certain cases
- How Medicare billing activity may be considered in the broader enforcement process
Who Should Read This
- Health care compliance professionals
- Medical coders and auditors
- Health care attorneys
- Provider enrollment and billing staff
- Fraud and abuse investigators
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