Sanction Screening – Frequently Asked Questions

Please describe your capabilities with respect to screening for the types of individuals and entities that health care institutions are required to check (employees, contractors, volunteers, physicians, and vendors).2017-05-10T19:05:25+00:00

OIG Compliance NOW provides comprehensive screening service for all types of individuals and entities, including employees, physicians, referring physicians, volunteers, and vendors/contractors (entity names as well as employees). We would support health care institutions in providing all individuals and entities with a clear and conspicuous disclosure, in writing, that the OIG Sanction Report will be obtained for monthly sanction screening purposes, and such disclosure would be contained in a document containing only this disclosure. We would also advise health care institutions with regard to other disclosures and other applicable state and local laws for the type of report requested, including all disclosures which are required before requesting that OIG Compliance NOW prepares the Sanction Report and before taking any adverse action based in whole or in part upon any information contained in the Report.

What is the typical turnaround time to process and complete a screening request?2017-05-10T19:05:42+00:00

Turnaround time for list screening is 48 hours; validation activities will require more time and will depend on resource availability at federal and state program integrity unit offices.

What details are provided in your reports (i.e., matches only, explanation of sanctions associated with a match, etc.)?2017-05-10T19:05:47+00:00

Any client with validated exclusions will first be contacted by telephone prior to the generation of the monthly report. When an association match is found, an OIG Compliance NOW investigator takes that record and verifies that the employee or vendor is sanctioned and/or excluded. After all of the association matches have been investigated and verified, a final report is generated. The final report includes a positive match report including a “snapshot” report from the individual (state) OIG/GSA/State database. All verified data includes, name of sanctioned person or entity, owner of entity, reason for sanction, verification of name(s) or entity name, date of birth, social security number, EIN or TIN, dates of sanction and state of sanction. Positive matches will be listed in detail for follow up and reference. The state level name association matches are verified through verbal conversation with a contact at the state(s) Medicaid/Medicare Program Integrity Unit. OIG Compliance NOW captures these results to their database and includes this in the deliverable report.

Please describe additional resources or capabilities that you offer (if any) to your clients to help them stay abreast of new requirements, changing regulations, etc., on this subject at both the Federal and state levels.2017-05-10T19:05:52+00:00

We are prepared to offer clients a comprehensive compliance solution for sanction screening which includes a sanction screening checklist, quarterly updates of new requirements/regulations, and an annual review of the program to encourage the development of a long-term, “best practice” compliance program. We stay connected to various federal, state and professional organizations to stay alerted of changing regulations and practices.

For entities with offices or branches in more than one state, what is your capability (if any) for checking sanctions against both the overall corporate entity as well as individual offices or branches?2017-05-10T19:05:57+00:00

Our comprehensive screening process effectively checks for sanctions of entities including all offices and branches in any part of the United States.

What is your mechanism (if any) for ensuring that an individual or entity who shows up as excluded on one of your reports, but is cleared by the health care institution, does not show up on subsequent reports?2017-05-10T19:06:02+00:00

Our standard procedure is to report all active exclusions that appear in our monthly search results. However, using our unique and proprietary OIG Investigations tracking system, we are able to automatically identify individuals that were investigated in previous months and list those individuals as “previously identified and reported to client”. In terms of “clearing” excluded individuals and allowing them to work within the Medicaid system, regulations do state that an exclusion can be overcome when OIG finds that significant factors weigh against exclusion. In the case where a health care institution client feels that a sanctioned individual or entity can be “cleared” to work, OIG Compliance NOW will contact OIG to discuss the factors in greater detail, which will involve: circumstances of the misconduct and seriousness of the offense; the individual’s role in the case of a sanctioned entity; the individual’s actions in response to the misconduct; and other information about the entity. It may be permissible for the health care institution to apply for a waiver for the excluded individual.

If there is a match on an individual list (including state lists), what assistance can your company provide to help the health care institution to acquire the information needed to verify the match?2017-05-10T19:06:07+00:00

Part of our validation process includes obtaining documentation from local, state and federal agencies regarding the nature of the exclusion. We then share this documentation with the health care institution as part of our master validation report.

If and how you confirm the identity of an excluded individual or entity in order to distinguish between an excluded individual or entity and others with the same or similar names, etc.2017-05-10T19:06:11+00:00

Results are ALWAYS VALIDATED before any communication back to the health care institution. Names of excluded individuals and entities are confirmed to be accurate through a manual investigative process that involves verbal communication with local, state and federal agencies, as required.

How do you confirm the identity of an excluded individual or entity if there are individuals or entities with the same or similar names?2017-05-10T19:06:17+00:00

Results are ALWAYS VALIDATED before any communication back to the health care institution. Names of excluded individuals and entities are confirmed to be accurate through a manual investigative process that involves verbal communication with local, state and federal agencies, as required.

What is meant by an “Effective” compliance program?2017-05-10T19:06:23+00:00
  • The organization exercises due diligence to prevent and detect inappropriate conduct by the Medicaid provider

  • The organization promotes an organizational culture that encourages ethical conduct and is committed to compliance with the law.

  • The compliance program is reasonably designed, implemented, and enforced so that the program is generally effective in preventing  and detecting improper conduct.

Failure to prevent or detect specific offenses does not necessarily mean that the program is not generally effective in preventing and detecting such conduct.

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