A Simple Guide to Exclusion Screening and Vendor Compliance Screening

The operation of any business, particularly in health care, has two important components: providing care to patients and customers, and abiding by regulations. An especially important set of regulations to comply with is to fully understand who you are hiring and who you are conducting business with, commonly referred to as performing "Exclusion Screening."

Exclusion screening may seem intimidating if you are not familiar with the term, but it is quite an easy process. It is similar to performing a background check, but much more specific. The Government has a list of individuals and businesses that are excluded from participating in Federal Health Care Programs, and as such; you must check the list for your potential employees and business partners before hiring or contracting with them. This blog will serve to help you learn why it's so essential to check this exclusion list.

What is Exclusion Screening?

Exclusion screening is simply checking your employees against federal and state databases to check if they have been excluded from working in healthcare.

Individuals can be "excluded" for different reasons: fraud, physical abuse of a patient and defaulting on a student loan, for example. If someone is on this exclusion list, it signifies the government has determined "this person is a risk to us by using our federal funds."

Hospitals and clinics cannot afford to employ an excluded individual. If you hire someone who is excluded from participating in Medicare or Medicaid and send a claim to either of these programs for their services, you are violating the law. There can be substantial financial penalties for this. Therefore, Exclusion Screening is a regular occurrence in HR offices throughout the United States.

Why You Need OIG Screening

When we talk about these checks, the biggest name that comes up is the OIG (Office of Inspector General). OIG Screening refers specifically to checking the list maintained by this federal body.

The OIG maintains a list called the LEIE (List of Excluded Individuals/Entities). It is updated every single month. This is why doing a check once, when you first hire someone, is not enough. A nurse or a billing manager might be in good standing when they start working for you in January, but they could get into trouble and end up on the list by June.

To stay safe, organizations must perform OIG Screening on a regular basis—usually once a month. This ensures that you don't accidentally employ someone who has recently been banned from the industry.

Don’t Forget to Perform Vendor Compliance Screening – You Screen For Your Employees, But What About Your Vendors? Many Organizations Perform Vendor Compliance Checks

Typically, when you hire physicians, you screen them. When you hire nurses, you check their history. When it gets to other people you do business with, many organizations will forget about these individuals. This is where vendor compliance screening comes into place.

Your organization works with many outside partners. Examples might include a temporary staffing agency that provides you with temporary workers or a vendor that supplies your medical equipment or the billing company that processes your bills and money.

If any of these vendors are on an exclusion list, that is the same as hiring an excluded employee. Doing business with them can carry the same penalties as hiring excluded team members. Performing vendor compliance screenings will verify that the vendors you are paying are also eligible to receive funds from the government.

For example, if you utilize a transportation service to transport patients to appointments and that vendor is excluded from receiving funds you are using to pay them from a federal source, you will have to reimburse the government for those payments plus penalties.

What Is At Risk If You Skip These Checks?

You may think, "Is it really going to happen that I would hire someone from this list?" Unfortunately, yes - and quite often! There are many names included on these lists, and they get updated on a regular basis.

When you do no Exclusions screening, you are making a financial gamble. There can be penalties that exceed thousands of dollars for each violation when employing an excluded worker. For a busy hospital, such fines can sum into the millions very quickly. In addition to the monetary cost, there is also damage to the reputation of the facility. Patients expect to feel secure in knowing that those who provide care for them have not committed illegal acts of misconduct.

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Conclusion

Compliance doesn't have to be scary. It is just a matter of building good habits. By understanding the importance of OIG Screening and making sure you look at both your staff and your vendors, you protect your business.

Remember, Exclusions screening isn't just about avoiding fines. It is about maintaining high standards. It ensures that the people working in our healthcare system are trustworthy, safe, and qualified to be there.