Healthcare · Compliance
False Claims Act and OIG exclusions
The contract-operations view. The vendor relationship registry defines the exclusion-screening universe, and the arrangements registry is the audit target under a Corporate Integrity Agreement.
Regulatory requirements for contract management
These are the requirements that bear on contracts and the contract record. It is general information, not legal advice.
- The False Claims Act (31 USC 3729-3733) imposes treble damages plus per-claim penalties; qui tam provisions let whistleblowers file on the government’s behalf.
- Employing or contracting with an excluded person can create civil monetary penalty exposure where federal-program payment is sought for what that person furnishes or causes (42 CFR 1001.1901).
- Screening runs against a broad universe: the OIG List of Excluded Individuals and Entities, GSA SAM.gov, the CMS Preclusion List, OFAC Specially Designated Nationals, and the 40-plus state Medicaid exclusion lists.
- A Corporate Integrity Agreement, typically 3 to 5 years, adds Independent Review Organization audits, named-executive certifications, annual board resolutions, and reportable-events obligations.
How a compliant program operates
The contract-side cadence a well-run program runs on.
- Every employee, physician, vendor, contractor, board member, owner, and subcontractor is screened at hire and monthly, with each event documented.
- The vendor scope is defined broadly, because supply-chain exclusion exposure is the gap most likely to generate penalties.
- Under a Corporate Integrity Agreement, the arrangements registry supports the Independent Review Organization audit and a disclosure log captures reportable events within the required window.
- Self-disclosure through the OIG or CMS protocols is built into the program as a multiplier-reduction pathway.
Is your exclusion-screening record audit-ready?
If you cannot check every box, the whitepaper shows how leading programs close the gap.
How Contract Logix supports the work
Contract Logix maintains the complete vendor relationship registry that your screening tool pulls through configurable APIs and connectors as a clean source-of-truth counterparty universe, tracks physician compensation arrangements in a form that can serve as the Focus Arrangements Tracking System a Corporate Integrity Agreement requires with rollup by referral source, and provides configurable dashboards and a six-year audit trail for Compliance Committee and Board reporting. Contract Logix holds the registry the screening tool pulls; it does not itself screen for exclusions. Explore the repository, workflow, the Contract Intelligence Engine, and the Contract Intelligence Dashboard.
Get the full False Claims Act and OIG exclusions whitepaper
The whitepaper covers the operational requirements, the regulatory citations and deadlines, and where compliance programs most often fall short, with the contract-operations view throughout.
Frequently asked questions
Does Contract Logix screen vendors for exclusions?
No. It holds the vendor registry your screening tool pulls as a clean source of truth. The screening runs in your screening tool.
Can it support a Corporate Integrity Agreement?
Yes. The arrangements registry can serve as the Focus Arrangements Tracking System, with a six-year audit trail and Board reporting.
Where does the disclosure log live?
In the compliance case-management system. Contract Logix supplies the contract-side data that supports disclosure entries.
Disclaimer. This page is general information about the False Claims Act and OIG exclusions and contract operations. It is not legal advice and does not create an attorney-client relationship. Consult qualified counsel for advice on your obligations.
