Medicare/Medicaid payment for items or services furnished or ordered by an excluded individual or entity is prohibited.

“The effect of an OIG exclusion is that no Federal health care program payment may be made for any items or services furnished (1) by an excluded person or (2) at the medical direction or on the prescription of an excluded person. The exclusion and the payment prohibition continue to apply to an individual even if he or she changes from one health care profession to another while excluded. This payment prohibition applies…even if the payment is made to a State agency or a person that is not excluded.”

“For example, no payment may be made to a hospital for the items or services furnished by an excluded nurse to Federal health care program beneficiaries, even if the nurse’s services are not separately billed and are paid for as part of a Medicare diagnosis-related group payment received by the hospital. Also, the excluded nurse would be in violation of her exclusion for causing a claim to be submitted by the hospital for items or services the nurse furnished while excluded.” OIG Special Advisory Bulletin on the Effect of Exclusion From Participation in Federal Health Care Programs (May 8, 2013) p. 6