Monthly OIG Exclusion Checking: Mandatory or Optional?

Posted by Frank Strafford on December 28, 2014 in Exclusion Screening,

Monthly OIG Exclusion Checking: Mandatory or Optional?

Are monthly exclusion screening checks mandatory?  According to healthcare compliance experts, the vast majority of facilities are just not doing them…

The following post on HCCAnet, the health care compliance expert, caught our eye.

“How many times are you conducting exclusion checks on your employees and vendors?  I know it’s been recommended that we conduct exclusion checks once a month.  I would think that is rather expensive from an operations perspective. -Martin”

Fair question, particularly from someone who has little experience with exclusion screening checks and software.  It was the answer, posted by Compliance Professional Frank Ruelas, that raised our eyebrows.

“I can tell you on an estimation basis, about half do quarterly checks, one quarter each 6 months, and very few on a monthly basis.”

Telling data, indeed!

Just for the record, Illinois, the state of origin of the questioner, updates its Provider Sanctions list on a monthly basis, and clearly states that “Program payment will not be made to any entity in which a listed individual is serving as an employee, administrator, operator or in any other capacity for any services, including administrative and management services furnished, ordered or prescribed on or after the effective date of the sanction or voluntary withdrawal. Also, no payment may be made to any business or facility that submits bills for payment of items or services provided by such an individual or entity.”

Which means that Martin is playing quite a risky game.  At best, claims that the facility submits on behalf of any as-yet-undiscovered excluded individual will be denied, leaving the facility holding the bag for several months’ worth of services.  At worst, the facility may be hit with one of those infamous OIG fines – and claims of ‘We checked half a year ago and she was fine!” are just not going to make the cut.

So why aren’t more facilities playing it safe, and conducting exclusion screening checks on a monthly basis?  Simple.  Their compliance officers are under the impression that responsible, foolproof, monthly OIG exclusion checks must be either ridiculously cumbersome or prohibitively expensive.

We don’t like to toot our own horn on this blog, but… they’ve obviously never met Streamline Verify.

Please refer to this resource for more helpful information on OIG Exclusions and LEIE searches.

About Frank Strafford

About Frank Strafford

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