URMC Compliance Program Policy Manual:
Debarment and Exclusion from Medicare, Medicaid and Other Federal or State Grants and Programs

Federal law makes it illegal for anyone who is not in good standing with federal agencies to provide services under Federal Health Care Programs like Medicare or Medicaid or to work on government funded grants or contracts.  Individuals who are subject to these restrictions are generally described as having been “excluded”, “suspended” or "debarred."

There are very severe civil and criminal penalties for violating these laws.  For example, if an excluded or debarred individual provides health care services paid for by a federal program, his or her employer might have to return the payments it received from Medicare or Medicaid for this person’s services. Similarly, the salary support a university received from an NIH, NSF or other federal grant might have to be returned to the federal government.  The entire hospital and/or university could also be prohibited from participating in Medicare and Medicaid, from working on government grants and contracts, and from receiving other financial support.

Examples of persons who may be excluded suspended or debarred may include those who have:

  • committed certain Medicare, Medicaid or Federal Health Care Program infractions;
  • defaulted on student loans or other government loan obligations;
  • been disciplined or sanctioned by a government agency;
  • lost or surrendered their license to practice a profession such as medicine or nursing (even if the license has been restored).
  • been indicted or convicted of certain crimes,
  • been the subject of certain civil or administrative proceedings or penalties.

The University of Rochester and its health care affiliates use a number of means to detect and prevent prohibited conduct.  But those efforts cannot be completely effective without your help. 

We ask that you assist us by doing the following:

  • If you have been excluded, suspended or debarred or know someone who works for the University who has been excluded, suspended or debarred, IMMEDIATELY notify the Compliance Office at 275-1609, Office of Counsel at 275-8019 or Integrity Hotline at 756-8888 (anonymous reports accepted).
  • When you are re-credentialed or are applying for federal grants or contracts, please read and complete all forms carefully. Many forms specifically ask about exclusion, suspension, debarment, and other important matters.  These forms are one of the most important safeguards against prohibited behavior.
  • If you have any doubts about whether you or anyone working for the University of Rochester or one of its affiliates is excluded, suspended, or debarred, IMMEDIATELY bring the matter to the attention of the Compliance Office (275-1609) or the Office of Counsel (275-8019).
  • If you are excluded or debarred, do not make assumptions about what you can or cannot do.  These issues are very complex.  Problems with one agency may affect your relationship with other agencies.  Exclusion from Medicare or Medicaid may impact job duties that are not related to Federal Health Care Programs.  Even state programs and grants and contracts with other institutions may be affected.  Make the Compliance Office or Office of Counsel aware of these issues so that they can be evaluated carefully.

For your reference, you may also consult the web sites maintained by the General Services Administration and the Office of the Inspector General of the Department of Health and Human Services for more information.

  • Whether or not you consult those web sites, you should bring your questions to the Compliance Office or Office of Counsel.