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/policies/administrative/uwmf/uwmf-wide/compliance/103006.policy

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Policies,Administrative,UWMF,UWMF-wide,Compliance

OIG Exclusion Checks (103.006)

OIG Exclusion Checks (103.006) - Policies, Administrative, UWMF, UWMF-wide, Compliance

103.006

POLICY & PROCEDURE




Effective Date:

April 1, 2015

Compliance

Policy #:
MF

Original


Title: OIG Exclusion Checks


I. PURPOSE

The Office of Inspector General (OIG), which is part of the U.S. Department of Health and
Human Services (HHS), is charged with eliminating fraud, waste, and abuse in Medicare and
other HHS programs. Among other powers, OIG has authority to exclude individuals and
entities from participating in federally-funded health care programs, including Medicare.

OIG maintains a List of Excluded Individuals and Entities (LEIE). Entities such as the University
of Wisconsin Medical Foundation, Inc. (UWMF) who participate in federal programs face
significant monetary penalties for purchasing goods or services from anyone on the LEIE, and
may also face program exclusion themselves.

This policy implements new internal procedures to ensure that UWMF does not purchase goods
and services from vendors and service providers on the OIG exclusion list.

II. POLICY

UWMF maintains a compliance plan in order to detect and prevent fraud and abuse. To avoid
contracting with individuals or entities on the LEIE, this policy implements a process to ensure
that all contracts or engagements are checked against the LEIE. Every employee who wishes
to retain, or enter into a new contract with, an individual or entity on behalf of UWMF must follow
the procedure set forth in Section III of this policy.

III. PROCEDURE

If you are retaining an entity, you are required to perform the OIG exclusion check for the name
of the entity and for any individuals identified by that entity who will be providing any of the
services to UWMF. In order to perform a search for the name of the individual or entity, go to
the OIG website at http://exclusions.oig.hhs.gov/ and confirm that the individual or entity is not
listed on the LEIE.

If the individual or entity is listed, or you are not sure, contact the UWMF Compliance Officer. If
the individual or entity is not listed, print screen the result. To do a print screen – Go to File >
Print Preview>Select Landscape and click the printer icon. Once this is done, send the print
screen result with the vendor set-up forms, including Form W-9, to Accounts Payable at
AccountsPayable@UWMF.wisc.edu. This will confirm that the OIG exclusion check has been
completed. You may then proceed with the contract or engagement.

Accounts Payable will keep a record of exclusion checks and results.




Questions about the LEIE or this process may be directed to the UWMF Compliance Officer.
(Mary Waldo, Compliance, at Mary.Waldo@uwmf.wisc.edu or (608) 821-4137)

Questions about vendor set-up may be directed to the UWMF Accounts Payable Supervisor.
(Lisa Ayala-Oliva, A/P, at Lisa.Ayala-Oliva@uwmf.wisc.edu or (608) 821-4805)

VI. COORDINATION

UWMF Sr. Management Sponsor: Steven P. Means, Vice President of Legal Services &
Compliance

UWMF Reviewers: Mary Waldo, Compliance Officer
William Young, Associate Legal Counsel
Lisa Ayala-Oliva, Accounts Payable Supervisor

UWMF Approval: Peter H. Christman, Executive Vice President and Chief
Operating Officer
Robert W. Flannery, Vice President Finance




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