Civil Monetary Penalty
also known as: CMP · CMP exposure
A federal financial penalty imposed for employing or contracting with an excluded provider, among other violations.
A Civil Monetary Penalty (CMP) is a financial penalty that HHS-OIG can impose for a range of healthcare violations, including knowingly employing or contracting with an individual or entity that is excluded from federal healthcare programs.
If an excluded person furnishes items or services that are billed — directly or indirectly — to a federal healthcare program, the employer can face CMPs of up to roughly $20,000 per item or service, plus treble (3×) the amount claimed. Liability attaches even when the employer did not know of the exclusion, if the OIG determines they should have known through reasonable screening.
This penalty structure is the core financial reason organizations screen their workforce and vendors against the LEIE monthly and keep an audit trail of each screen.
EXAMPLE
A clinic that billed Medicare for services rendered by an excluded medical assistant for six months could face CMPs far exceeding the salary it paid.RELATED TERMS
Screen a provider against the Civil Monetary Penalty
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