Must Haves for a Proper Exclusion Screening Process
At Exclusion Screening, LLCSM, we know the ins-and-outs of the exclusion screening process. In our opinion, an effective screening process requires some mandatory tools. To ensure that there are no holes in your screening process make sure you have:
1 – A List of Employees and Vendors
All providers need a complete list of employees and vendors. Your Exclusion Experts here at Exclusion Screening, LLCSM will ensure that you aren’t missing any vendor that may present a liability. We know that it may be difficult to think of every possible contractor that directly or indirectly furnishes an item or service that is payable by the Federal health care programs. That’s why we guide our clients through the list making process.
If you choose to do your own screening, you must ensure that you have the following pieces of information for all employees and contractors: full name, maiden name, date of birth, address and Social Security Number.
2 – Access to Exclusion Lists
Providers who perform their own screening will need to have the ability to access the online state and federal databases. At a minimum, providers should check their employee and vendor lists against the OIG-LEIE, GSA-SAM, and the 37 state Medicaid Exclusion Lists.
3 – Time and Ability for Exclusion Screening
Finding time for monthly checks may be difficult, but it is critical. Employing one excluded person can cost a provider tens of thousands of dollars.
Proper exclusion screening is going to take a decent chunk of one employee’s time. If you do not have a staff member to completely commit to screening then consider outsourcing this job to a professional exclusion screening company.
5 – The Budget
Conducting monthly exclusion screenings will cost money regardless of whether you choose to screen in house or contract the job out. While it may seem like a hefty expense, if OIG discovers that you employed or contracted with an excluded individual or entity, you will be liable to pay Civil Monetary Penalties of up to $10,000 per item claimed and assessments of up to three times the amount of each item claimed. As Benjamin Franklin said, “An ounce of prevention is worth a pound of cure.”
Ensuring that your exclusion screening process contains these five elements will keep your practice compliant and off of OIG’s radar. If dedicating your resources and time to effective exclusion screening seems to overextend your practice consider outsourcing the job to Exclusion Screening, LLCSM. Contact us today at 1-800-294-0952 or fill out our service form.
Ashley Hudson, Associate Attorney at Liles Parker, LLP and former Chief Operating Officer for Exclusion Screening, LLC, is the author of this article.