CMS issued a State Medicaid Director Letter (GDMS) in 09 recommended that states require providers to screen all employees and contractors monthly. However in 2011, CMS issued final regulations requiring states to track all registered providers each month. In addition, Article 6501 of the PPACA requires states to terminate individuals or entities from their Medicaid programs if the persons or entities were arrested by Medicare or other Medicaid States. This becomes the "excluded in one, excluded in all" principle.
So what's the skinny Medicaid checks exclusions in terms of best practices? If you provide services to Medicaid recipients in your state, you must determine if your state has specific requirements for screening exclusions and sanctions, and if the state maintains its own database, or downloaded their data the list of OIG excluded individuals and entities. (FIRA). The list OIG exclusions has been a subject of our last message.
Medicaid Exclusion Checks best practices
According to David Servodidio Trust provider, there are currently 27 state Medicaid exclusion lists that exist. And, in theory, according Servodidio, these lists should report any exclusions to the FIRA OIG timely. trust provider has researched (which he describes as digging) and came up with the following:
Many state Medicaid exclusion lists do not report to the OIG FIRA timely or at all. As the industry leader in respect of health care, we decided to put together a list of best and worst state medicaid exclusion lists, based on how reliable they are to report to BIG timely. Let's start with the best. When it comes to reporting on those excluded from the OIG, state Medicaid Here are the top exclusion lists:
- Hawaii - 88%
- Connecticut - 69%
- Maryland - 60%
- Nevada - 59%
- Michigan - 55%
This is the worst state Medicaid exclusion lists for reporting excluded the BIG timely:
- West Virginia
- Alabama
- Indiana
- Nebraska
- Tennessee
- Massachusetts
- SC
- Washington
the bottom line: the verification of the BIG database is not sufficient to ensure compliance with Medicaid exclusion controls. You might have to check all state Medicaid exclusion lists available on a monthly basis in addition to the database of the OIG exclusions when hiring new employees. Keep in mind that the scalability of your clinic and organization. Large suppliers may want to avail of a service, as trusted supplier if a large number of employees, and / or a monthly turnover. Small suppliers that probably need to check when hiring and annually.
Make sure that the compliance strategy and monitoring and audit factory covers all potential sources of exclusion on a monthly basis, and that includes all currents (27) State Medicaid Exclusion Lists .
Do you provide Medicaid services? Did you check all your employees against your state Medicaid exclusion list (for the 27 that exist). You document your compliance with exclusion audits?
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Nancy Beckley
Nancy J. Beckley is the president of Nancy Beckley & Associates LLC, a firm specializing in compliance with outpatient therapy. The firm offers outsourcing the compliance risk assessment, compliance plan development, annual compliance training, and external audit, due diligence and investigative support. Customers are suppliers under Medicare review of the probe, the plans of progressive corrective actions, corporate integrity agreements, ZPIC investigations and RAC audits.
Nancy background includes 15 hospital years experience in the service management capabilities to two large rehabilitation facilities for inpatients with extensive managed care contracting and program management expertise. A therapist in the background and training, Nancy served as program director, director of the institution and administrator in both rehabilitation facilities for inpatients and outpatients.
She is a nationally recognized speaker in the field of rehabilitation of compliance, and presented to the Conference Provider Practice Compliance, Florida Compliance Conference, and the Healthcare Compliance Compliance Institute Association. It was described in a Healthcare Compliance Association webinar on the risk of hospitalization in outpatient therapy, and wrote three articles for compliance Today and written over 20 articles on the RAC program.
Mrs. Beckley area of expertise includes:.
• Development of the compliance program, consulting, training, and the external auditor
• Medicare Regulatory requirements for suppliers outpatient therapy, including extensive experience in the investigation and Medicare certification for outpatient treatment providers
• auditing and consulting commitments under attorney-client privilege for risk assessment and the analyzes the potential recovery of responsibility
• Medicare program integrity initiatives: MACs, RACs, CERTs, ZPIC, critics of the probe before and after payment of examinations
• recognized expert national level on CORFs, served on the technical expert Group Medicare CORF
• outpatient Hospital board compliance, audit and training
• compliance diligence activities due in the acquisition and portfolio development to assess compliance risk Medicare
EDUCATION: University of South Florida, MBA; Harvard School of Public Health course for managed care executives; University of Illinois, m.s. University of Wisconsin, B. s
PROFESSIONAL ASSOCIATIONS: Board of Directors, National Association of Rehabilitation Agencies (NARA) Members, Healthcare Compliance Association; Contributing Editor principal RAC Monitor + monitor Monday; Compliance columnist for IMPACT Journal of APTA
PROFESSIONALCERTIFICATIONS: CHC, certified Health compliance by the Healthcare Compliance Certification Board
PUBLICATIONS AND PRESENTATIONS: Available on request
CONTACT: 414-748 -4376; Nancy@NancyBeckley.com;
Latest posts of Nancy Beckley (see all )
- Call Medicare Denials - 5 things you need to know - June 18, 2014
- therapy PQRS Panic - June 5, 2014
- Medicare Confusion G code - May 28, 2014
- Medicaid exclusion controls - May 7, 2014
- Checking Importance Exclusions - April 30, 2014
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