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Q&A: Reporting Exclusions from Federal or State Health Care Programs
- Does an exclusion from participation in a federal or state health care program have to be in effect for a certain amount of time before it must be reported to the NPDB?
- The OIG pursued civil money penalties and exclusion against a physician because the physician and his medical practice allegedly billed Medicare improperly. The physician and his medical practice agreed to settle the case. The settlement did not include findings or admissions of liability, but the physician agreed to pay $100,000 for allegedly violating the Civil Money Penalties Law and agreed to be excluded from Medicare, Medicaid, and other federal health care programs for 3 years. Should the civil money penalty or the exclusion, or both, be reported to the NPDB?
- A physician was indefinitely excluded from a state Medicaid program because her medical license was suspended in another state. Should this exclusion be reported?
- The OIG pursued civil money penalties and exclusion from Medicare, Medicaid, and other federal health care programs against a physician because of allegations that the physician and his medical practice improperly billed Medicare. The physician appealed the decision to impose a civil money penalty and exclusion to the HHS Departmental Appeals Board. The administrative law judge assigned to the case found in favor of the OIG and upheld the imposition of the civil money penalty and exclusion against the physician. Should these actions be reported as an "other adjudicated action or decision," as an exclusion, or both?
- The owner of a medical supply company was found not guilty of violating the False Claims Act in regard to fraudulent Medicare claims, but the OIG excluded the company from participating in the Medicare program. Should the exclusion be reported to the NPDB?
