OIG Background Check Basics:
Not every medical practice is large enough to employ a full-time compliance officer, but every medical facility is large enough to get slammed by the OIG for messing up on some part of the screening process.
Over the course of the past couple of months, the Office of the Inspector General has been making a point of going after small medical practices and individual doctors; even going so far as to issue a special fraud alert directed towards individual physicians in early June. The penalties for inadvertently hiring or contracting with a flagged employee include lengthy litigation, bad publicity, and — of course — hefty fines to the tune of tens (or hundreds) of thousands of dollars.
For medical offices struggling to manage with a limited number of staff members, pre-employment background screening requirements can be a pain. But it doesn’t have to be. Whether or not your office boasts a bona-fide compliance officer, here are a couple of employee background screening tips for you.
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Know who’s responsible.
Who is responsible for background screening? The compliance officer? The HR manager? The long-suffering secretary who plays both of those roles? Any of the above is a perfectly good answer, so long as the responsible party knows that he or she IS the responsible party!
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Create protocol.
This is a lot easier than it sounds. There’s no need for comprehensive meetings or discussions. Essentially, all you have to do is make a list of the required background screenings in your state, along with links to the appropriate verification sites. Do it once, and you’ll have it for always! For those in the dark, here is our short list of essentials:
- License check. Every potential applicant should be providing you with a copy of his or her license. Most states have a portal where you can look up the status of licenses for free, so you’ll want to be sure to connect with yours.
- Criminal background check. Criminal background verification requirements vary by state. If your state offers its own criminal background verification site, you’ll be able to work with that; otherwise, you’ll need to partner with a third party vendor who offers these services.
- Exclusion screening check. Even individuals with clean criminal histories may be excluded from participation in federal and/or state healthcare programs due to a variety of misdemeanors, which such as narcotics addiction or defaulting on a student loan. Employers are required to check both the federal List of Excluded Individuals and Entities (LEIE), as well as individual state databases; you can access a list of state databases by scrolling down to the bottom of this page. (Private companies offer software to help you out with this, so that you don’t need to start the whole process from scratch each time the list is updated – which happens monthly.)
(Note: Large corporations with full-scale compliance programs typically perform a number of additional searches – such as e-verify, sex offender list, social security number lookup, and more – for every employee, on an ongoing basis. We chose to limit our short list to the three essentials, because we recognize that for the small business, multiple rigorous searches may not be practically feasible without employing the services of a third party vendor.)
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Keep a log.
Attach your newly-created list to each applicant’s employment application, and have the responsible person at your office check off each screening once it’s done. Copies of the results should be printed and placed in the employee’s folder as well.
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Screen all employees and vendors.
Screen everyone you contract with, including vendors and side-partners such as ambulance drivers. Even if they are not directly employed in a medical capacity, they may still be excluded from participation in Federal healthcare programs, and facilities that mistakenly contract with them can be slammed with fines up to $2 million. (See infographic for listing of fines in 2014.) Hopefully, with your newly streamlined pre-employment screening protocols, that will never happen to you.
About the Author:
Steven Grossman is Director of Operations at Streamline Verify, a company that offers background credentialing and exclusion screening software and services to the healthcare industry. An affiliate of the Health Care Compliance Association, Steven has had a hand in pioneering Streamline Verify’s groundbreaking credentialing software, and shares responsibility for oversight of all facets of Streamline Verify’s customer relationships.
