Dear Friends,

I have some news that may be upsetting. Frankly, that is my intention, to frighten you into action.

In August, a Home Health provider in New York paid an $$866,339.25 fine for violating the “Civil Monetary Penalties Law.”* The Chinese-American Planning Council Home Attendant Program had employed an individual, in connection with the New York State Consumer Directed Personal Assistance Program (CDPAP), who was excluded from participation in the New York Medicaid program and was not eligible to furnish services under the CDPAP.

Georgia provider Agape Hospice Care paid $250,993.97 in penalties, the specific amount it had paid in salary and benefits to two unlicensed nurses.

If this law is unfamiliar to you, it is the requirement that you may not employ any individuals who are not eligible to work within the Medicare system.*

This is only one example of a new OIG crackdown!

  • Bridges MN, a non-profit with services to the disabled, was fined $150,171.96 for employing a single excluded individual.
  • Vicki Roy Home Health Service paid a $38,000 fine for employing one excluded caregiver.
  • Providence Health System-Southern California, doing business as Providence Little Company of Mary Medical Centers, which includes two hospitals, agreed to pay $141,562 in connection with the employment of an excluded emergency services technician from Aug. 8, 2016, to June 5, 2019. (Note that this person was employed for nearly three years without the health system knowing, as they are required to know, that he or she was excluded.)
  • Joseph Health Personal Care Services, doing business as Nurse Next Door, agreed to pay $32,244 in connection with the employment of an excluded constant care attendant from Nov. 2, 2017, to Aug. 8, 2019.

My friends, the list goes on and on, and these are just the Home Health agencies:

  • Serenity Home Healthcare Services Agreed to Pay $146,000
  • Professional Home Health Care 2: $77,000
  • Chinese-American Planning Council Home Attendant Program: $866,000
  • Visiting Angels of Rhode Island: $158,000

I learned of at least 25 other healthcare providers that were fined under this law. Clearly, the HHS OIG is on the warpath. This is not a regulation you are wise to ignore.

That is why I write you today. I have found an affordable service that performs monthly OIG exclusion screening for you. Doing it yourself would require a dedicated FTE and hours of painstaking work.

I would be honored if you would accept my introduction to the company that provides this service. If the fines I listed above grabbed your attention, you can see that a service of this type is like an insurance policy that costs a fraction of the disaster it can prevent.

The company is called Carosh Compliance Services. The monthly service is called “OIG Express.” I know and trust the founding CEO, Roger Shindell. To contact Roger and learn more about this necessary service, use this link:

Tim Rowan
Editor Emeritus
The Rowan Report