It is a common assumption that the majority of providers on the OIG List of Excluded Individuals/Entities (LEIE) arrived there by defrauding the Medicare/Medicaid systems. It turns out that program related crimes are the second most common reason for exclusion. The most common reason why providers are excluded is due to license revocation or suspension. Below are the top 5 exclusion types and their descriptions:
Drilling down on why a given provider’s license was revoked or suspended is not always easy. The reasons for these revocations and suspensions are many. Often times, the notes or minutes coming from the state licensing board do not specify a reason as the relinquishment may have been voluntary. Additional digging is often required to get the full picture.
Let’s look at an example:
Malissa Bender, was recently excluded on the OIG List. She was excluded because the Florida Board of Pharmacy granted a “Voluntary Relinquishment of License” tendered by the provider in October, 2013. Additional internet research reveals that Bender was arrested in July 2013, for stealing schedule II and III drugs from the Pharmacy where she worked. (see story)
With over 25,000 providers excluded for type 1128b4 you can see how tedious case-by-case research can become to get to the bottom of each exclusion. Fortunately, in most cases, simply knowing that the provider’s license is suspended or revoked should be enough for most employers to take action. In some cases, the reason for revocation or suspension will not be due to criminal action, or any other reason known to the employer. This fact emphasizes the need for employers to monitor an employee’s license and exclusion status.
TyphoonData offers solutions for license and exclusion monitoring.
If you would like to discuss our thoughts and solutions, give us a call at 800-780-5901.