Beth Israel Deaconess Medical Center is a Federal Contractor and as such is committed to ensuring our compliance with the Office of Inspector General (OIG) and the US General Services Administration (GSA) in its effort to identify and eliminate fraud, waste, and abuse in the workplace; and to promote efficiency in its operations.
The OIG and GSA have been given the authority to exclude individuals or entities who have engaged in fraud or abuse from participation in Medicare, Medicaid, other Federal health care programs, and other Federal government programs; and to impose civil monetary penalties (CMPs) on the individual and employers for certain misconduct related to Federal health care programs and other Federal government programs.
Statement of Intent
It is the policy of Beth Israel Deaconess Medical Center to not employ nor contract with individuals or entities that are excluded or otherwise ineligible from participation in Federal Health Care and other government programs.
Furthermore, BIDMC requires all employees/entities to report their exclusion status to the Chief Compliance and Privacy Officer within 5 business days of its occurrence.
The Medical Center's exclusion checking requirements are designed to ensure that BIDMC employs/contracts with individuals/entities that are trustworthy, law abiding, and committed to upholding the Medical Center's compliance standards.
Examples of Items/Services
Here are examples of some types of items/services that are reimbursed by Federal health care programs which, when provided by excluded individuals/entities, violate the OIG and GSA exclusion and which may subject the Medical Center to possible fines.
- Services performed by excluded nurses, doctors, pharmacists, technicians, secretaries, social workers, janitors, chefs, phlebotomists or other excluded individuals who work for health care organizations, where such services are reimbursed directly or indirectly by a Federal health care program, even if the individuals do not furnish direct care to Federal health care program beneficiaries;
- Items or services provided to a program beneficiary by an excluded individual who works for an entity that has a contractual agreement with, and is paid by, a Federal health care program; and
- Services performed by an excluded administrator, billing agent, accountant, coder, auditor, claims processor or utilization reviewer that are related to and reimbursed, directly or indirectly, by a Federal health care program.