decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Special Advisory Bulletins / OIG Special Advisory Bulletin 99-2_Sept 28, 1999 / CMP Liability for Employing or Contracting with an Excluded Individual or Entity
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Article Overview
This article reviews an OIG Special Advisory Bulletin addressing civil monetary penalty exposure tied to employing or contracting with excluded individuals or entities. It is relevant to compliance staff, providers, contracting entities, and billing organizations that work with federal health care programs. The bulletin discusses the legal standard referenced by OIG, the potential penalty framework, and the importance of verifying exclusion status before entering into relationships that could affect federal program reimbursement.
Why This Topic Matters
Organizations involved in hiring, credentialing, contracting, or claims submission need to understand exclusion-related compliance risk because it can affect reimbursement, penalties, and program participation.
What You Will Learn
- The compliance risk associated with employing or contracting with excluded individuals or entities
- The federal program exclusion framework discussed by OIG
- The general civil monetary penalty concerns highlighted in the bulletin
- Why exclusion status checks matter before establishing employment or contractual relationships
Who Should Read This
- Health care providers
- Compliance officers
- Billing and reimbursement staff
- Contracting and credentialing teams
- Healthcare legal and compliance professionals
Codes Discussed
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