Navigating Healthcare Compliance: Why Every Clinic Needs an OIG Check List and Routine Sanction Checks

Selecting the right candidates is crucial across all industries; however, when it comes to selecting employees within the healthcare field, it becomes especially important due to a multitude of safety and compliance-related concerns associated with these employee decisions. When hiring an employee (e.g. a nurse, physician, coder/biller) to work in a medical practice or hospital, employers not only seek candidates with strong work skills but also have to consider whether prospective employees are trustworthy people who are legally certified to work in the healthcare industry. Because of the legal consequences of failing to perform adequate pre-employment screenings, clinics cannot rely on conventional methods of conducting criminal background checks to safeguard themselves from hiring bad employees. Thus, healthcare employers must follow rigorous federal guidelines in order to avoid legal issues related to hiring employees.

Identifying Bad Actors

The government's Office of Inspector General (OIG) recognizes the importance of preventing healthcare fraud and abuse against federally funded government benefits (i.e. Medicaid and Medicare). If a healthcare provider has been convicted of Medicaid fraud, abusing patients, or illegally dispensing controlled substances, there are many penalties for those employees, including an exclusion from employing anyone associated with a clinic or provider that provides services to Medicaid or Medicare recipients.

To prevent accidental hiring of those who are banned, as part of the hiring process, HR must do an OIG Check which searches through the Federal Government's database of Excluded Individuals. If a clinic skips this step and hires a banned individual, it could incur severe fines that would put their business in jeopardy.

Moving to the Next Step

The federal Government database is a great way to start, but it is only one piece of the puzzle. Some states have sanctioned or banned healthcare workers through state databases and also through medical board actions. This is why trusted organizations conduct Comprehensive Sanction Checks on all of their employees to verify they have no sanction placed against them by any state or national authority.

Sanctions refer to the penalty put on an individual for a disciplinary action taken against their license. Comprehensive checks look at databases at the Federal, State and Professional Licensing Boards to ensure that the applicant has a clean record at all levels.

Organizing the Monthly Screening Process

Healthcare compliance can be complicated because someone’s circumstances can change in an instant. A nurse can have a 100% clear background check at time of hire; six months later that same nurse may have been sanctioned or banned. If you only run a background check on your employees at time of hire, then you are exposing the clinic to significant potential liability.

Thus, keeping organized is extremely important. Skilled health care managers have a detailed OIG check list. This is a complete, ongoing database on every employee, vendor, contractor and volunteer associated with the clinic. Instead of just looking up names at the time of hire, healthcare facility managers use the total listing of staff and all affiliated persons to query their names through the state and federal databases each month.

Peace of Mind

Healthcare rules can feel confusing and overwhelming, but they exist for a good reason. By understanding the importance of federal database exclusion screening, keeping a well-organized monthly list, and running broad state and federal checks, clinics protect their patients from harm. Even better, they protect their own business from accidental legal trouble and massive financial penalties. Regular screening is simply the backbone of a safe, honest healthcare system.

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