OIG Increases The Number Of Exclusions By 25 Percent In Fiscal Year 2014

On October 31, the Department of Health and Human Services Office of Inspector General released their fiscal year (FY) 2015 Work Plan. The Work Plan is released at the beginning of each fiscal year to set forth new and existing projects planned for the coming year. The projects highlighted in the Work Plan are conducted out by the Office of Audit Services, Office of Evaluation and Inspections, Office of Investigations, and Office of Counsel to the Inspector General and includes scheduled projects under the Centers for Medicare & Medicaid Services.

The Work Plan also highlights achievements accomplished during (FY) 2014. Here are some noteworthy accomplishments by the numbers.

• $15.7 billion savings estimated on the basis of prior-period legislative, regulatory or administrative actions as a result of OIG’s recommendations.
• 4,017 individuals and entities excluded from participation in federal health care programs.
• 971 criminal actions taken against parties that participated in crimes against HHS.
• 533 civil actions related to false claims and unjust-enrichment lawsuits, civil monetary penalties settlements and administrative recoveries as the result of self-disclosures.

Year after year these above figures continue to increase. The growth in savings, the rising number of individuals and entities being excluded, the increasing number of criminal and civil action all point to a more proactive and engaged OIG.

If we specifically look at the number of excluded individuals and entities, it is ever increasing. Looking back 10 years, to the FY 2005 Work Plan, the OIG did not even specify how many parties were excluded. Rather it only stated that “we anticipate reviewing and implementing the exclusion of several thousand providers.” It was not until FY 2008 that the OIG began stating how many parties have been excluded. This shows, going forward, exclusions would be an area of focus for the OIG.

During FY 2013, 3,214 individuals and entities were excluded. The OIG increased the number of individuals and entities it excluded in one year by almost 25 percent. As a provider or entity operating in the healthcare industry you should take notice. What this shows is that the OIG is increasing their exclusion activity. And, the flip side, is that the OIG is also taking action against organizations that are employing or engaging with these excluded individuals.