Medicare/Medicaid payments are prohibited to healthcare providers if an excluded individual or entity is serving in an executive or leadership role or providing other administrative and management services for the provider.

“Excluded persons are prohibited from furnishing administrative and management services that are payable by the Federal health care programs. This prohibition applies even if the administrative and management services are not separately billable.

• For example, an excluded individual may not serve in an executive or leadership role (e.g., chief executive officer, chief financial officer, general counsel, director of health information management, director of human resources, physician practice office manager, etc.) at a provider that furnishes items or services payable by Federal health care programs.
• Also, an excluded individual may not provide other types of administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to Federal health care programs.”   OIG Special Advisory Bulletin on the Effect of Exclusion From Participation in Federal Health Care Programs (May 8, 2013) 7