Reducing Risk Through Robust Healthcare Personnel Screening

By Sue La Bonté, RHIA, CHP

2016 Alliance sponsor feature article provided by Favorite Healthcare Staffing

With the widely publicized episodes of Medicaid and Medicare fraud in recent years, there is increasing pressure on healthcare institutions to perform more frequent sanction screenings of employees and vendors against Federal and State exclusion lists, in order to ensure that they are not billing for the work of excluded parties.

Protect Yourself from High Dollar Consequences

Organizations that are audited and discovered to be billing for services rendered by an excluded vendor or individual will be fined ($11,000 per occurrence) and will be excluded from participating in federally-funded health care programs.

The consequences of employing or contracting with an excluded individual or entity include the following:

  • Reporting and repayment of all monies received by the excluded individual or entity, within 60 days,
  • $5,500 to $11,000 fine for EACH item/service claimed or “caused to be” claimed,
  • Extension of the existing exclusion period, or a new exclusion imposed by OIG for the individual/entity, and
  • Possible criminal false claim situation under FCA (False Claims Act), which is a separate basis for administrative sanctions and exclusions.

Federal and State Exclusion Lists

The OIG & GSA search utilizes the US Department of Health and Human Services, General Services Administration, and the Office of Inspector General’s databases for individuals and businesses excluded or sanctioned from participating in Medicare, Medicaid, or other federally funded programs. If an organization employs an individual on these sanctioned lists they may be forced to pay back all Federal funds received via these programs going back to the date the person was employed. Therefore, the OIG and GSA search is vital for healthcare industries.

OIG List
Refers to the List of Excluded Individuals/Entities (LEIE) maintained by the Office of the Inspector General, U.S. Department of Health and Human Services. Individuals on this list are excluded from participating in these programs: Medicare, Medicaid, Maternal and Child Health Services Block Grants, Block Grants to States of Social Services, and State Children’s Health Insurance Programs.

GSA List
Refers to the Excluded Parties List System (EPLS) maintained by the Federal government (General Services Administration). Individuals on this list are excluded from participating in Federal contracts. This list also includes data from the Department of Treasury’s Office of Foreign Assets Control (OFAC) List.

Favorite Healthcare Staffing has been providing healthcare personnel through per diem, contract, temp to perm, and direct hire to healthcare organizations for over 35 years. Favorite Healthcare Staffing understands the risk associated with improperly screened healthcare personnel.

As a routine part of our pre-employment screening, Favorite conducts an OIG-GSA review on all healthcare individuals. Additionally, Favorite performs reference checks, background checks, drug screens and a comprehensive interview conducted by trained recruiting professionals. Utilizing an external organization to perform this critical screening allows physicians and their staff to keep the priority and focus on the care of the individuals they see in their offices and clinics. Favorite Healthcare Staffing helps physician offices and clinics mitigate risk by ensuring staff and healthcare providers have passed all sanctioned screenings and exclusion lists.

This article is authored by Sue La Bonté, Executive Director of Human Resources and Quality Assurance at Favorite Healthcare Staffing. Favorite Healthcare Staffing offers MGMA members preferred pricing on a comprehensive range of staffing services to help physicians improve cost control increase efficiencies, and protect their revenue cycle. For more information, contact Paul Brown, Carolinas Regional Director at 913-800-7058.

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