How often should providers check if employees are on the OIG list of excluded individuals after hiring?

The recommended practice is for providers to check if employees are on the Office of Inspector General (OIG) list of excluded individuals on a monthly basis. This frequency helps ensure that any employees who may have been added to the list after their initial hiring or during their employment can be promptly identified.

The OIG maintains a list of individuals and entities that have been excluded from participating in federal healthcare programs due to various reasons, such as fraud, patient abuse, and other criminal offenses. Regular monitoring ensures that the organization remains compliant and minimizes the risk of having excluded individuals providing services that could lead to legal and financial repercussions.

While other frequencies such as weekly or quarterly monitoring may seem reasonable, they either introduce unnecessary administrative burden or do not meet the recommended level of diligence needed for compliance. Annual checks may not be sufficient to catch updates in a timely manner, potentially exposing the provider to significant risks. Therefore, a monthly review is the best practice for maintaining compliance with OIG regulations.