If an individual is working strictly in research and utilizing federal grants, would the exclusion provisions apply?
Again, it comes down to payment. If the person is supported wholly or in part through Medicaid funding, exclusion provisions apply. This is for the OMIG list only. Check with the federal funding source and ask what their policy is for federal health care dollars. • Do we have to keep all results of monthly searches, and, if yes, for how long? Answer: While there are no set requirements for retaining all results, they may be helpful in providing evidence of your compliance program effectiveness. Part 521 requires that providers maintain evidence of maintaining an effective compliance program, and screening for excluded providers is one component of an effective compliance program. • If we are doing our own manual screening, how do you recommend we provide proof of our efforts? Do you want us printing out each search we do and the confirmation of our efforts if the person/entity is excluded or not? Answer: The process you use for your own record-keeping is up to you. Again, we recommend
