Are your vendors poised to dump your facility into hot water?
Not that we’re suspicious, you understand.
Your vendors are reputable — right? And skilled. And low-cost, to boot. Surely, you did your due diligence on all of these counts before entering into contract with them.
But…
Does each one of your vendors perform an equally rigorous background check on each one of the many and varied individuals in their own employ? Is it possible…could it happen…that one of those stellar companies unsuspectingly hired an excluded individual?
Of course it’s possible. It’s even probable. Considering the skyrocketing numbers of excluded individuals, it’s virtually inevitable that amongst the hundreds of health care workers employed by your many vendors, there will be at least one excluded individual who slips through the cracks. Unless, of course, the vendor has an airtight exclusion check policy in place.
Well, you are probably thinking, Why would I care? If the vendor gets nabbed, he will have to carry the consequences; no skin off MY back.
If only it were that simple!
According to the law, facilities may be held responsible for all employees that provide services to their clients– even those employees provided through outside vendors. Naturally, the Federal government will not provide reimbursement for services provided by excluded individuals, regardless of your facility’s innocence in shelling out those funds in advance. Furthermore, it may hold you accountable for contracting with an excluded individual in the first place.
Happily, the solution is fairly simple; and here it is:
Merely insert a clause into all of your contracts, requiring the vendor to perform regular exclusion checks on its employees. Furthermore, the contract would require the vendor to indemnify your facility, should they be caught with an excluded individual on staff.
It’s that easy. Because compliance is all about the buck stopping HERE…long before it comes back to bite you.
