Due Diligence

Medicare/Medicaid Exclusions List and List of Parties Excluded From Federal Procurement and Nonprocurement Programs

The Sentencing Guidelines of 1991 mandate reduced penalties if certain directives are followed such as the implementation of an effective compliance program. Furthermore, the Sentencing Guidelines define the necessary elements for a compliance program. Due diligence as it relates to the delegation of discretionary authority to employees is one of these necessary elements.

The Office of the Inspector General (OIG) directs that, at a minimum, all personnel involved in the billing of a federal program must be investigated through the Medicare/Medicaid Exclusions List and List of Parties Excluded From Federal Procurement and Nonprocurement Programs. This includes all physicians, physician extenders, technicians, coding, billing, financial and administrative personnel.

BHS maintains the on-line database of physicians, private individuals and organizations that have been excluded from participating in all Health and Human Services programs. This database is updated monthly. BHS customers can check this database to verify whether physicians, physician office employees, hospital billing office personnel, compliance staff and other individuals have been excluded from federal programs. Once the absence/presence of the individual has been verified, the exclusion history tool will allow you to print a certificate that verifies the date and outcome of the search. This certificate should then be retained in case of audit.

Protect yourself from future problems. Click here to purchase access to this valuable service and begin screening employees today.

To check your existing staff or for other large searches, we recommend you contact us before entering the information manually.   We may be able to perform a complete search using your existing employee database.  To learn more, visit our  Composite Searches page.