Using the OIG’s Exclusions Database

Using the OIG’s Exclusions Database


My name is Andrea Berlin and I am an attorney
with the Office of The Inspector General. Did you know that if you employ an excluded
individual or contract with an excluded entity it could cost you money, and potentially a
lot of money? As explained in more detail in the podcast
regarding exclusion, you could be liable for Civil Monetary Penalties, and you may not
be able to get a provider number. In other words, it could potentially cost you hundreds
of thousands of dollars. So, how do you make sure that doesn’t happen
to you? You check the OIG’s Exclusions Database,
also known as the LEIE, which is short for the List of Excluded Individuals and Entities.
This list is free, simple, and easy to use, and it is easy for us to tell if you didn’t
check it. Now I am going to show you how to use the
website to protect yourself and your business. First go to www.oig.hhs.gov. Then, go to the right, and click on the box
on the right with the big red “X” labeled Exclusions Database. As you can see, you can screen five names
at one time. Remember to screen owners, managers, and officers
of the company. In other words, screen your boss. I’ll screen my boss, Lewis Morris. As you can see, I’ve made a spelling mistake
with his first name, so I will just hit the clear button, and that will erase everything,
and I can start over. Remember to screen yourself as well. I‘ll
enter my name now. You should also screen any other names used,
such as aliases, hyphenated names, and maiden names, so I will screen my maiden name, “Treese.” By using “Treese,” the entry would also
pick up “Treese Berlin” or any other entry that begins with the word “Treese.” In fact, here is a great tip: just type the
first few letters of the last name with no first name to cast a wider net. Why would you want to do that? Well, casting a wider net should catch if
an individual is trying to mask their exclusion by changing the spelling of their name or
their first name. Some excluded individuals are very tricky. They try to get a job without
disclosing that they are excluded. In order to do that, they might slightly alter their
name. In other cases, individuals may not recognize that a legitimate name change could
be problematic. In order to avoid these issues, you should always ask employees for any other
names used, and screen those names against the database. It is also important to note that you do not
need to capitalize letters in the names of the individuals or entities in order for the
search to work, but you do need to include punctuation. For example, if searching for
the name “O’Conner,” remember to include the apostrophe. You can also use the database to check the
names of businesses. I will check Forest Park. When checking the name of a business, your
search must begin with the first letters in the entity’s name. For example, beginning
your search with the word “Dental” would return any entity named “Dental Care Unlimited,”
but would not return “Unlimited Dental Care.” Lastly, for good measure I will show you what
happens when you check a common name like James Smith. I’ll use the name “James” to limit the
matches for demonstration purposes. However, someone named James could use the names James,
Jimmy, or Jim, so what you need to do is use the letter “J” or leave the first name
blank to cast a wider net. So now we can hit search and here are the
results. Luckily, as you can see from the top, there
are no hits for me or my boss. There is, however, a hit for Forest Park,
and there are multiple hits for James Smith, so let’s click on the first “James Smith”
result. Now we can verify if this is the same person
by entering the Social Security Number. I will use 1-2-3-4-5-6-7-8-9 and then click
“Verify”. And here we see what we expected – no match.
We didn’t expect a match because we didn’t think that anyone would have the social security
number 123456789 Also, when you look at an entry, never rely
solely on the address. People move all the time, so just because James Smith was from
North Carolina at the time of his exclusion, that doesn’t mean he is not the same Jimmy
Smith applying for a position in Oregon. Also, you’ll notice that it lists his occupation
as Nursing Profession. That does not mean he won’t be applying for a non-licensed
position now, or have a different type of licensure. Further, the prohibition doesn’t apply just
for the area in which the excluded person previously worked, so, for example, if James
Smith is hired to work maintaining medical records in a hospital, the hospital would
still be liable. Now let’s talk about some other great features
of the web site. If you click on “Exclusions” and pull down the dropdown menu, you’ll
be able to see lots of cool additional information. For example, you can select the LEIE Downloadable
Database. Here you can download the database to Excel
or Access. That way you can screen many more employees at one time. However, it’s important
to remember that these are not self-executing programs, you have to extract the information
and put it in Excel or Access. For example, if you click on the LEIE Database EXE link,
you will be asked if you want to run or save the document. Click “save.” Once it has been saved you
will get another prompt. Click “run.” Some people have reported that they have trouble
trying to use the “run” function. If you do have trouble, you can also go into Excel
or Access and try to open the saved database that way. Now let’s go back to the Downloadable Database
main page. While we are here, you will also notice there are monthly updates. It’s important
to note that those monthly updates do not include the complete database. Rather, they
only show the names that have been added and removed from the selection this month. Next we’ll go back to the Exclusions drop
down menu again. And you can see that there are a lot of other
features available. For example, you can look up “Background Information” on Exclusions
or you can learn about “Applying for Reinstatement.” Also make sure you review the Frequently Asked
Questions and the Quick Tips. Some key tips are: First, screen prospective employees and vendors
before hiring, and screen all existing employees and vendors regularly. Second, be smart about screening all possible
names against the database. Ask employees to tell you former names, such as maiden names,
so you can also check those against the database. Third, remember to double check spelling. Fourth, do not forget to take the final step
of identity verification using the SOCIAL Social Security Number or Employer Identification
Number, or EIN. It’s not sufficient to simply match a first name and last name on the LEIE.
Also, if you find a potential match using the Downloadable Data file, you must still
verify those results by entering verifying information online. That’s because The Privacy
Act prohibits us from including social security numbers in the Downloadable Data file. Fifth, document your efforts. If there is
ever a problem, you may need to prove to us that you properly screened someone. And, as
I mentioned before, it is easy for us to tell if you haven’t. If you do find out that an employee is excluded,
consider removing that employee from his or her role in your organization. Also, consider
whether you should initiate bill holds or disclose the matter to the OIG through the
OIG’s self-disclosure protocol, which is the subject of a separate podcast. If you have any questions, contact us and
we’d be happy to help. Costly lessons can be easily avoided. We want to make sure that
you have all of the resources you need to protect yourself and your business.

Danny Hutson

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