John Falcetano (john.falcetano@brooksrehab.org) is Director Corporate Compliance at Brooks Health System in Jacksonville, FL.

A critical element of any effective compliance program is monitoring. As a service to our members, each month this column focuses on potential monitors for specific business lines.

An important part of a compliance program is to ensure you do not have anyone working for your organization who has been excluded from participating in federally funded programs. This month, the focus is on exclusion monitoring. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) has the authority to exclude individuals and entities from federally funded healthcare programs and maintains a list of excluded individuals and entities. If your organization hires an individual or entity that is excluded, the individual or entity is prohibited from providing services that receive reimbursement from a federally funded program, and your organization may be subject to civil monetary penalties.