Payment Matters: Many State Medicaid Agencies Require Providers to Perform Monthly Exclusion Checks


Many State Medicaid Agencies are now requiring enrolled providers to perform monthly exclusion checks to determine if their employees or contractors are excluded from receiving payments from federal health care programs.

In an effort to strengthen the integrity of the Medicaid program and help States reduce improper payments to providers and suppliers, effective March 25, 2011, CMS implemented final regulations that require State Medicaid Agencies to screen all providers, suppliers, and persons with ownership and/or controlling interests, by checking the Office of Inspector General List of Excluded Individuals and Entities (Exclusion List) and the General Services Administration’s Excluded Parties List System (EPLS). This screening is required upon initial enrollment and monthly thereafter for as long as that provider is enrolled in the Medicaid program. In the preamble discussion, CMS recommends that States “consider making this a requirement for all providers and contractors, including managed care contractors in their Medicaid programs and CHIP.” According to CMS, many State agencies already made it their policy to require enrolled providers to do monthly exclusion checks based on prior CMS guidance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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