Question

A physician practice hired a consultant to perform external audit services for their practice. After the consultant began working, the OIG and GSA lists were checked and it was found the consultant was excluded from participation. What steps should the practice take?

Answer 1

If a hired consultant is on the OIG and GSA exclusion lists, the physician practice must stop their work, report the issue, conduct an internal review, examine contracts and payments, seek legal advice, and implement corrective actions.

Step-by-step explanation:

If a physician practice discovers that a consultant hired to perform external audit services is on the OIG (Office of Inspector General) and GSA (General Services Administration) exclusion lists, the practice should take immediate steps to rectify the situation. Here is a step-by-step approach:

1. Cease the Consultant’s Work: Immediately stop any work being performed by the consultant to prevent further potential legal issues or fines.
2. Notify Relevant Authorities: Report the incident to the OIG and any other relevant bodies, as retaining an excluded individual may lead to sanctions or penalties.
3. Conduct an Internal Review: Investigate how the oversight occurred to improve future hiring processes and compliance checks.
4. Review Contracts and Payments: Examine any payments or claims made to the excluded consultant and take appropriate actions, which might include repayment if federal funds were involved.
5. Seek Legal Advice: Consult with a healthcare attorney to understand the legal implications and next steps.
6. Implement Corrective Measures: Based on the internal review and legal advice, take corrective actions to prevent reoccurrences.

It is crucial to address such issues promptly and thoroughly to comply with federal regulations and avoid compromising the practice's integrity and financial standing.