As interpreted by the OIG, the law prohibits hiring, contracting with, or arranging for excluded individuals or entities to perform administrative, managerial, or volunteer services related to items or services payable by federal health programs. Excluded individuals can work in non-Federal health care program payment settings or provide care to non-Federal health care program beneficiaries. Also, there are some non-patient care employment options which wouldn't give rise to liability, such as facilities management or graphic design services.
