As a member of the elite "OIG Exclusion" group
- I am all the time searching for any updates to the OIG regs. Lo and behold, just a few days ago I stumbled upon an article outlining proposed changes to current OIG regs regarding early reinstatement that were released in May 2014. Please see for yourself:
In the article there is also a link provided to the actual Federal Register document:
To find the new proposals for early reinstatement you will want to go immediately to page 15 of the document Sec. 1001.501; and Sec. 1001.3002(b) which is found on page 18.
Keep in mind that this proposal for early reinstatement is for professionals (in our case nurses) who have absolutely no intention of reinstating their original license. But there is a catch, at least from what I understand. The catch is that this applies to individuals who have gone on to obtain licenses with another professional licensing board (e.g., pharmacy, physical therapy) and upon full disclosure to that licensing board of the original circumstances surrounding loss of the original license, no adverse action is taken by the new licensing board. Among other requirements, you have prove that the underlying problem that caused the original license to be suspended or revoked has been resolved. Hence, you have to prove that you are in recovery, have recovered, etc., etc.
Sounds goofy, doesn't it. It raises several questions for me.
1) How can you obtain a professional license from another licensing board without first disclosing that you lost another professional license? Every professional licensing board from doctors to nurses to lawyers to teachers requires this disclosure.
2) How can you complete a degree for a professional license (e.g., pharmacist, physical therapist, counselor) without completing some form of internship that would require you to enter into a facility from which you are forbidden due to the OIG exclusion?
My situation is like most everyone else here in this forum. License suspended 5 years ago, went to a 6 month treatment program, attend meetings, have 2 home groups, sponsor, accountability network, and have been in counseling for roughly three years. I just celebrated 5 years clean and sober in September. I am taking care of the problem. I have accepted responsibility for my choices and continue to take appropriate action.
Nearly three years ago, I decided to abandon nursing altogether, take what medical knowledge, people knowledge, and addiction experience I had and pursue a degree in professional counseling. Whatever time I have left on earth I could use to help at least one person. Only through a background check with the school I attend did I learn I had a criminal record with the OIG Exclusion list. Like many others, I was served a letter at the beginning but honestly did not understand the full scope of the exclusion. Once I saw the results of the background check, it all came back to me. I thought for sure there had to be a resolution. Nope. I have completed every requirement for my counseling degree BUT the internship portion because I cannot find a site to get the 600 hours I need to finish that does not deal with government funding. How about them apples?? Essentially I am at an impasse so back in May (coincidentally) I decided to go ahead and work toward getting my nursing license reinstated since that is the only way to clear your name. I have had little success finding any type of employment. One has to wonder if even a simple department store runs a background check and discovers you have a criminal record that you were never charged, tried, nor convicted for in front of a judge or jury of your peers for.
That takes me back to my original questions. I cannot even complete the degree to apply for the professional license. How in the world would anyone else have been able is beyond me.
I appreciate anyone and everyone who took the time to read this. I beg of you, please read the links I posted. I would be so appreciative for anyone's input, thoughts, and insight into this new change. I am definitely going to follow up. How long before you pay your debt?