Mondaq September 20, 2022
On April 1, 2019, the Center for Medicare and Medicaid Services (“CMS”) announced a new exclusion sanction: the CMS Preclusion List. This lesser-known sanction is different than placement on the Office of Inspector General (“OIG”) Exclusion List that is familiar to providers and administrators in the healthcare realm, and preclusion usually goes hand-in-hand with a CMS revocation. A comparison of the differences between the OIG exclusion, CMS revocation, and CMS preclusion processes is helpful to understand the consequences to providers who receive these sanctions and to healthcare entities who need to screen their providers to prevent incorrect and potentially fraudulent billing to federal payors.
The Exclusion Process
All providers who enroll with a federal healthcare program can be subject to...
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