Medicare Program Integrity Manual (Pub. 100-08), Ch. 4 § 4.10.2.5.1
Denial of Payment to Employer of Excluded Physician
4.10.2.5.1 - Denial of Payment to Employer of Excluded Physician
(Rev. 11032; Issued: 09-30-21; Effective: 10-12-21; Implementation: 11-10-21)
If an excluded physician is employed in a hospital setting and submits claims for which
payment is prohibited, the MAC surveillance process usually detects and investigates the
situation.
However, in some instances an excluded physician may have a salary arrangement with
a hospital or clinic, or work in group practice, and may not directly submit claims for
payment. If this situation is detected, MACs:
• Contact the hospital/clinic/group practice and inform them that they are
reducing the amount of their payment by the amount of federal money
involved in paying the excluded physician
• Develop and refer to the UPIC as a CMP case.
Upon referral from the MAC, the UPIC shall finalize the case and refer it to the OIG.