OIG’s Quarterly Enforcement Actions Against Organizations That Hire Excluded Individuals

The Department of Health and Human Services Office of Inspector General (OIG) has been active during the last quarter of 2024 and first quarter of 2025, cracking down on healthcare providers who employed excluded individuals. In all cases, the healthcare organizations knew or should have known that the individuals were excluded, and in many of the cases, the healthcare organization self- disclosed the conduct to the OIG. 

Recent OIG Enforcement Actions 

• On January 6, 2025, Adriana Strimbu, DPM, agreed to pay $41,000 for allegedly violating the Civil Monetary Penalties Law by employing an excluded individual. 
• On December 31, 2024, Falanda Shelton agreed to be excluded for 7 years for allegedly paying improper renumeration. 
• On December 30, NormaTec agreed to pay $198,000 for allegedly violating the Civil Monetary Penalties Law by submitting claims for DME supported by fabricated medical records. 
• Also on December 30, 2024, Sharp Healthcare agreed to pay $153,000 for allegedly violating the Civil Monetary Penalties Law by employing an excluded individual. 
• On December 17, 2024, Conservatory of Hope, Amber Galbraith, and Heath Lewis agreed to be excluded for 35 years for allegedly submitting false claims. 
• Also on December 17, 2024, Zavier Ash, MD agreed to pay $209,000 for allegedly violating tje Civil Monetary Penalties Law by receiving remuneration in exchange for prescribing medications. 
• On December 4, 2024, Freeman Health System – Freeman West agreed to pay $250,000 for allegedly violating patient dumping statute by failing to provide stabilizing treatment. 
• On October 23, 2024, Accura Healthcare Management Services and Accura Healthcare of Knoxville agreed to pay $60,000 for allegedly violating the Civil Monetary Penalties Law by employing an excluded individual. 

In several of the cases above, improperly hiring a single individual costs these organizations thousands of dollars. Specifically, in the case of Sharp Healthcare, they wrongfully employed an excluded individual, which cost them $153,000. Whether you conduct sanction checks in-house or outsource sanction checks to a vendor, the cost of the work is far less than the price ultimately paid by Sharp Healthcare

The OIG continues to crack down on providers who are improperly hiring individuals without conducting screenings against the List of Excluded Individuals and Entities. The OIG’s continued enforcement of screening requirements highlights their position of protecting federal healthcare programs’ beneficiaries and ensuring that excluded individuals do not fraudulently participate during their period of exclusion. 

Screening for program exclusions should be viewed by your organization, and especially by executive management, the compliance officer and the Board of Directors, as a necessary part of doing business in the healthcare industry. Individuals and businesses can be excluded for a number of reasons, i.e., offenses related to the delivery of care; patient abuse or neglect; fraud, theft and other financial misconduct; and felony convictions related to controlled substances. Therefore, to protect your business, and especially the welfare of your patients and employees, sanction screening is a necessary part of the business. 

Interested in learning more about Sanction Screening? Contact Shelby Cole at [email protected].