Why Run A Health care Sanctions Report?

In September 1999 the DHHS Office of Inspector General released a Special Advisory Bulletin concerning "The Effect of Exclusion From Participation in Federal Health care Programs." This document provided a more detailed explanation of when services rendered by an excluded provider are not reimbursable. Within the Bulletin it was made clear that not only were federal funds not to be used for individuals and entities directly involved with patient care, but that Civil Monetary Penalties (CMPs) could be imposed for using federal funds for excluded providers that were indirectly involved in patient care. In addition, "no federal program payment may be made to cover an excluded individual's salary, expenses or fringe benefits, regardless of whether they provide direct patient care."

It is extremely important for companies to be aware of excluded providers among hires and contractors due to potential CMP's as well as the possibility of an organization being excluded from participation in federal healthcare programs. As was reported in the media in 1998, there are other providers who have been the subject of adverse actions not taken by the federal government but by state licensing agencies. This second category of adverse actions could cause an organization to suffer monetary penalties as well, not necessarily from the government, but from civil suits and public relations problems.