Remark code N132 is an alert indicating that payments will no longer be made for services provided by a healthcare provider who has been debarred or excluded by the US Government. This code serves as a final reminder that there is a 30-day grace period, after which no further payments will be issued as previously notified. Providers receiving this code should take immediate action to address the exclusion issue if they wish to continue receiving payments for their services.
Common causes of code N132 are:
1. The provider has been placed on the exclusion or debarment list by a government agency, such as the Office of Inspector General (OIG) or the General Services Administration (GSA).
2. The provider's name matches an individual or entity on the List of Excluded Individuals/Entities (LEIE).
3. There may have been a failure to remove or report an excluded individual from the provider's employment or association after receiving notification of their debarment.
4. The provider may not have adequately responded to prior notifications regarding potential exclusion or debarment issues.
5. There could be an administrative error where the provider was incorrectly matched to a person on the exclusion list.
6. The provider may have overlooked or not received the initial warning or grace period notification, leading to a lapse in addressing the exclusion issue.
Ways to mitigate code N132 include implementing a robust compliance program that regularly checks the Office of Inspector General (OIG) Exclusion List and the System for Award Management (SAM) to ensure that all providers associated with your healthcare organization are not debarred or excluded. Establishing a routine verification process before hiring or contracting new providers and periodically throughout their tenure can help prevent this issue. Additionally, training staff on the importance of compliance with federal regulations and the consequences of employing excluded individuals can further reduce the risk of receiving code N132. It's also advisable to have a clear action plan for immediately addressing any instances where a provider becomes excluded, including reassigning patients and ceasing billing for the excluded provider's services.
The steps to address code N132 involve a multi-faceted approach to ensure compliance and restore the ability to receive payments. First, verify the accuracy of the exclusion status of the provider in question by checking the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE) and the System for Award Management (SAM). If the provider is indeed listed, immediately halt billing for services rendered by the provider to prevent further denials.
Next, conduct an internal investigation to understand the circumstances that led to the provider's exclusion. If the exclusion is found to be in error, gather necessary documentation and contact the appropriate agency to dispute the exclusion status. If the exclusion is valid, develop a corrective action plan that includes removing the provider from any direct billing to federal healthcare programs and reassigning their duties in a manner that complies with federal regulations.
Additionally, review and update your compliance program to prevent future occurrences. This should include regular checks of the OIG and SAM databases for all providers associated with your practice. Lastly, communicate with your billing and coding staff to ensure they are aware of the exclusion and the need to adjust billing practices accordingly. If necessary, provide additional training to staff to prevent future issues related to excluded providers.