The Office of Inspector General (OIG) for the US Department of Health & Human Services, which administers the Medicare and Medicaid programs in the United States, has the authority to exclude individuals and entities from Federally funded health care programs. This is the List of Excluded Individuals and Entities (LEIE).
An exclusion means that no payment will be provided for any items or services furnished, ordered, or prescribed by an excluded individual or entity. This includes Medicare, Medicaid, and all other Federal plans and programs that provide health benefits funded directly or indirectly by the United States.
…liability could result if the provider’s claim to the Federal health care program includes any items or services furnished by an excluded person, even if the excluded person does not receive payments from the provider for his or her services (e.g., a non-employed excluded physician who is a member of a hospital’s medical staff or an excluded health care professional who works at a hospital or nursing home as a volunteer). 1
OIG updates the LEIE monthly, so screening employees and contractors each month best minimizes potential liability.1
Best practices dictate that you should compare your volunteers against the LEIE list every month. You could use the OIG website and type in each name – every month – and check them.
VSys One can:
1 Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs, Issued May 8, 2013
VSys One can also download the exclusions file from SAM - the US government's "System for Awards Management". Whether or not you need to check your volunteers against that file as well is determined by your organization's rules.