CMS Pub. 100-08, ch. 4, § 4.10

The term “sanctions” represents the full range of administrative remedies and actions

available to deal with questionable, improper, or abusive practices of practitioners,

providers, and suppliers under the Medicare and Medicaid programs or any state health

care programs as defined under §1128(h) of the Act. There are two purposes for these

sanctions. First, they are designed to be remedial, to ensure that questionable, improper,

or abusive practices are dealt with appropriately. Practitioners, providers, and suppliers

are encouraged to correct their behavior and operate in accordance with program policies

and procedures. Second, the sanctions are designed to protect the programs by ensuring

that improper payments are identified and recovered and that future improper payments

are not made.

The primary focus of this section is sanctions authorized in §1128 and §1128A of the

Act (exclusions and CMPs). Other, less severe administrative remedies may precede the

more punitive sanctions affecting participation in the programs. The corrective actions

UPICs, SMRCs, and MACs shall initially consider are:

• Provider education and warnings;

• Revocation of assignment privileges;

• Suspension of payments (refer to PIM, chapter 3);

• Recovery of overpayments (refer to PIM, chapter 3); and

Referral of situations to state licensing boards or medical/professional societies.