Introducing Our New Service: Exclusion Screening for Healthcare Compliance

As healthcare providers navigate the complex web of rules and regulations in compliance, one aspect that needs more attention is exclusion screening of those working with federally funded healthcare programs. We’re excited to announce the launch of our new service, Exclusion Screening, that will assist healthcare organizations in adherence to requirements such as the initial screening of potential employees/contractors and monthly screening of current employees/contractors.

Understanding Exclusion Screening

Exclusion screening is the process of verifying that current or potential employee/contractor are not classified as an excluded individual or entity who is prohibited from participation in any Federal health care program. These programs are governed by regulations outlined in sections 1128 and 1156 of the Social Security Act, with oversight by the Office of Inspector General (OIG).

The OIG is authorized to exclude individuals and entities from federally funded healthcare programs. To uphold compliance standards, employers are required to conduct screenings for all new employees before extending offers of employment. Additionally, monthly screenings must be completed to align with the OIG’s monthly release of newly excluded individuals or entities.

Implications for Healthcare Practices

Anyone who hires an excluded individual or works with an excluded entity may be subject to civil monetary penalties, as such Total Medical Compliance’s solution will allow you to screen all new employees before an offer of employment is made or prior to entering into a contract with a Business Associate, as well as automate monthly screenings per the OIG’s monthly release of newly excluded individuals or entities.

Non-compliance with these requirements could result in financial penalties and jeopardize participation in Federal healthcare programs. Furthermore, per the OIG, no payments will be made for any items or services furnished by excluded parties, which includes Medicare/Medicaid and all other Federal health benefit programs.

Our Comprehensive Screening Process

At Total Medical Compliance, we understand the importance of OIG’s thorough screening. Our service checks all relevant databases, including:

• LEIE – List of Excluded Individuals and Entities
• SAM – System for Award Management
• 44 State Databases

This approach ensures that no excluded individual or entity slips through the cracks, safeguarding healthcare practices from financial penalties and maintaining program eligibility.

Differentiating Mandatory and Permissive Exclusions

The OIG has two different exclusions, mandatory and permissive – here’s how to differentiate between them:

• Mandatory exclusions are required by law and encompass individuals/entities convicted of specific criminal offenses related to healthcare fraud, patient abuse, felony convictions, and controlled substance violations.
• Permissive exclusions grant OIG discretion to exclude individuals/entities based on various grounds, including misdemeanors related to healthcare fraud, submission of false claims, and engaging in unlawful kickback arrangements.

The duration of exclusion varies based on the type of offense:

• Mandatory exclusions entail a minimum of 5 years on the exclusion list.
• Permissive exclusions typically range from 0 to 3 years.

Ensuring Compliance, Mitigating Risks

Our new Exclusion Screening service lets healthcare practices easily navigate the regulatory landscape associated with employees/contractors with confidence. We help organizations mitigate risks, uphold compliance standards, and maintain the integrity of Federal healthcare programs.

Compliance with exclusion screening requirements is not just a regulatory obligation; it’s a fundamental step towards ensuring ethical conduct and preserving the trust of patients and stakeholders. Request a free quote for our exclusions screening services or watch a video demonstration of what it entails.