Ask Mary | April 2025

Question: Are Medicare-Certified home health agencies required to check the OIG exclusion list for physicians who sign the patient’s plan of care?

Answer:  Yes!  The Social Security Act, 42 CFR 1001.190, specifically states “no federal healthcare program payment can be made for services directed or prescribed by an excluded physician.”  This requirement would also apply to an independent nurse practitioner or a physician assistant who is independently authorized or working under California Business and Professions Code, Section 2725 protocols which specify they may order home health services.