Why Should You Search State Exclusion Databases?
You know the OIG (Office of Inspector General) LEIE (List of Excluded Individuals/Entities) is the federal database for all Medicaid sanctions. However, did you know that many states maintain separate sanction/exclusion databases as well? These are investigations conducted by the state Medicaid offices, which do not always include participation by the federal Medicaid program.
So, why should you search the state databases in all states you operate or have a physical business presence? Why should you do this in addition to the federal databases? (Hint: because the OIG says so…)
According to the OIG’s Best Practices, you should also search state databases corresponding to your business or service delivery location(s) because state actions may appear prior to federal listings, and in some cases, the states and feds do not fully synchronize their entries. Yet if a person or organization you do business with is excluded by your state, even if they have not yet been added to the federal list, you will be required to repay all associated funding, plus interest and penalties that are typically many times the service value, and could even end up negotiating a three to five year Corporate Integrity Agreement.
You’ve taken the first step, searching federally. Finish the job, and search your state(s) too with the same easy EPStaffCheck tools and no extra work!