OIG Outlines Updated Criteria for Exclusion Authority

On April 18, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued a policy statement with updated, non-binding criteria it will use in assessing whether to exclude an individual or entity from Federal healthcare programs. The policy statement clearly articulates the five administrative options available to the OIG, ranging from complete exclusion to full release, and places them on a compliance risk spectrum with the former necessary for conduct that presents the highest risk to the Federal healthcare programs and the latter necessary for conduct that presents the lowest risk to those programs. In addition, consistent with the 1997 OIG criteria for implementing its permissive exclusion authority, the updated criteria set forth various factors that OIG considers in its determination of where a person falls on that compliance risk spectrum. For more information, please see Sidley’s recent Healthcare Update (available here), which outlines the new criteria and factors OIG considers in its determination of where a person falls on the compliance risk spectrum.

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