There are many lists that exclude individuals from participating in certain activities. It is the responsibility of the employer to make sure
an individual who will perform such activities is not only on such lists at the time they are hired for such work, but also the employer bears the responsibility
to assure that all their such employees remain off of these lists. The powerful MeSH system makes it practical to run all employees of a company on a regular basis
(e.g., monthly) to minimize the risk of fines and contract termination.
Office of Inspector General (OIG) via the List of Excluded Individuals and Entities (LEIE)
The OIG has the authority to exclude individuals and entities from federally funded health care programs pursuant to sections
of the Social Security Act and maintains a list of all currently excluded individuals
and entities called the List of Excluded Individuals and Entities (LEIE).
Since 2010, the OIG has fined more companies each year, with 94 companies being fined in 2014. Most of these are for only one individual found to be on the OIG list,
and the median fine is about $90,000. The risk-weighted fine easily justifies the cost of a MeSH monthly OIG screening program, plus you mitigate the risk of losing
part or all of your Medicaid funding.
If your company relies heavily on such funding (e.g., Medicaid), we strongly recommend you learn more about the MeSH
monthly OIG screening process.
US System for Award Management (SAM)
The System for Award Management (SAM) is the Official U.S. Government system that consolidated the capabilities of CCR/FedReg, ORCA, and EPLS.
SAM is combining federal procurement systems and the Catalog of Federal Domestic Assistance into one new system. This consolidation is being done in
phases. The first phase of SAM includes the functionality from the following systems:
Fraud and Abuse Control Information System (FACIS)
- Central Contractor Registry (CCR)
- Federal Agency Registration (Fedreg)
- Online Representations and Certifications Application
- Excluded Parties List System (EPLS)
This is a 3rd party private system which at its highest level accesses many federal and state databases. MeSH has integrated with this
company's system to provide instantaneous service via the patented MeSH order entry system for ease of use.
Terrorist Lists (Patriot Act) AKA The Office of Foreign Assets Control (OFAC)
The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces economic and trade sanctions based on
US foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those
engaged in activities related to the proliferation of weapons of mass destruction.
All businesses organized under U.S. law “…are responsible for ensuring that they do not undertake a business dealing with an individual or entity
on the SDN list” per the "Foreign Assets Control Regulations for the Corporate Registration Industry"
State Debarment Lists
In addition to Federal Exclusion Lists, states can also have their own exclusion lists. These can include Debarment, Suspension and Disqualification
for terms different than on any Federal list. They can exclude individuals from State Contracting (e.g., supply products or services to the state) and can
also include or be called State Medicaid Exclusions Lists
What is GSA, EPLS, SAM, and OIG?
The General Services Administration (GSA) administers the Excluded Parties List System (EPLS) and the System for Award Management (SAM), both of which
contain debarment actions taken by various Federal agencies, including exclusion actions taken by the OIG. The LEIE contains only the exclusion
actions taken by the OIG.
MeSH provides access to these and other databases via a highly proficient order entry and results delivery system. If you do not see the database
you are interested in above, please contact us below and we'll be glad to provide you with the information.
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