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Following the Money: Sanction Checks and Open Payments

  • Writer: venops431
    venops431
  • Mar 23
  • 2 min read

The healthcare industry is complex. It involves doctors, hospitals, pharmaceutical companies, and medical device manufacturers, all moving at a fast pace. Because there is so much money involved—and because patient health is at stake—there are strict rules about financial relationships and legal standing.

Two major components of keeping this system honest are sanction checks and the Open payments cms system. Let’s break down what these are and why they matter to your organization.


Understanding Sanction Checks


While we often talk about specific healthcare lists, the reality is that businesses need to look broader. Sanction checks refer to screening individuals and companies against a wide variety of disciplinary lists.

This goes beyond just healthcare fraud. Sanction checks look for:

  • Terrorist watch lists.

  • Money laundering databases.

  • Debarment lists (companies banned from doing business with the government generally).

  • State-level disciplinary actions (like a doctor losing their license in one state but trying to work in another).


If you are a compliance officer, running comprehensive sanction checks ensures that you aren't unknowingly employing someone who has been flagged for illegal behavior. It protects your organization’s reputation. If a hospital hires a surgeon who has been sanctioned in three other states for malpractice, the hospital could be liable for negligence.


The Era of Transparency: Open Payments CMS


Aside from criminal behavior, there is also the issue of conflict of interest. This is where Open payments cms comes into play.

Years ago, there was a concern that pharmaceutical companies and device manufacturers were influencing doctors by giving them gifts, expensive dinners, or speaking fees. The fear was that a doctor might prescribe a certain drug not because it was the best for the patient, but because that drug company took them on a nice vacation.

To fix this, the government created the Sunshine Act. This program is managed through the Open payments cms database.

Open payments cms is a federal tool that collects information about payments made by drug and device companies to physicians and teaching hospitals. This data is then made public.


  • For the Public: Patients can search the database to see if their doctor has received money from specific drug companies.

  • For Industry: Manufacturers must meticulously track every dollar, lunch, and travel expense they provide to doctors and report it to the CMS (Centers for Medicare & Medicaid Services).


Why It All Matters


Both sanction checks and Open payments cms are about integrity.

Sanction checks filter out the "bad apples"—the people and companies who have already broken the rules and need to be kept out of the system.

Open payments cms shines a light on relationships. It doesn't necessarily mean a doctor did something wrong by taking a consulting fee, but it ensures that the relationship is visible to everyone. It discourages "pay-to-play" medicine.

For any healthcare organization or life sciences company, staying on top of these requirements is mandatory. It requires modern software and a dedicated team. But ultimately, these tools help ensure that medical decisions are made based on science and patient needs, not on hidden payments or by people who shouldn't be practicing medicine.


 
 
 

Comments


OIG Excluded acts do not apply to those who work in a restorative capacity, which incorporates volunteers. This is to say that if a healthcare supplier utilizes an avoided person for an authoritative role, this is also grounds for a penalty. 

Understanding the ins and outs of the HHS OIG exclusion list is basic when overseeing your commerce. Make it beyond any doubt that your screening arrangements are up-to-date and that individuals on your staff know how to go about them.

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