Utilizing Third-Party Sanction Checks to Prevent Enforcement Actions

Overview

Many health care organizations are aware of the U.S. Department of Health and Human Services Office of Inspector General’s (HHS OIG) guidance on conducting regular sanctions and exclusion screening of all workforce members. However, these organizations may not realize that in order to receive the most accurate, objective results they should employ a third-party sanctions screening vendor to carry out the screening process for them. Utilizing a third-party vendor ensures that all sanction checks are conducted accurately by specialized, trained professionals. Contracting a third-party vendor to conduct screenings is also a proactive approach to remain compliant with federal and state program requirements. As long as an organization continues to meet all requirements and maintain an effective compliance program, it is preventing future enforcement actions that could have more serious implications.

What is a Sanctions Check?

Per the HHS OIG’s guidance, health care providers must conduct regular sanction checks of all workforce members, vendors, contractors, new hires, physicians, volunteers etc. to determine if any individuals or entities are excluded from participating in federal health care programs. The sanction check and screening process involves collecting names and identifying information from these parties, i.e. first, middle and last names, Social Security Number, date of birth, provider license number etc., and screening them against the names and information of excluded individuals or entities included in state and federal exclusion databases, such as the OIG List of Excluded Individuals and Entities or the General Services Administration System for Award Management.

If any party is found to be a positive match to a person or entity included on an exclusion database, then they have been involved in fraud, waste, abuse, or other unethical or illegal behavior to some degree in the workplace. Any organization that continues to employ or engage excluded parties is putting patients, customers, and other workforce members at risk. Utilizing sanction checks to identify and address excluded individuals and entities is crucial for health care organizations to ensure the workplace is safe, which can also limit the involvement of federal enforcement agencies who may otherwise implement more severe actions or repercussions for not meeting requirements.

Benefits of Third-Party Sanctions Checking Systems

In addition to ensuring an organization remains compliant with the HHS OIG’s guidance and preventing the involvement of enforcement agencies, third-party sanction checking vendors also have many other benefits, including:

  • Providing necessary independence and objectivity that separates the sanctions screening process from the organization.
  • Employing a sanctions checking system that searches batches of names and single names, multiple exclusion databases, and various kinds of screening criteria.
  • Utilizing professionally-trained and experienced sanction checking and screening associates.
  • Providing access to other valuable screening tools such as highly-developed sanction screening software.
  • Offering immediate and/or long-term services that are flexible, convenient and cost-effective.

In Review

Conducting effective sanction checks is not always easy. But organizations can utilize third-party vendors to carry out the sanctions screening process for them in order to meet federal and state program requirements. Third-party vendors’ qualified services and systems also help prevent enforcement agencies from seeking additional action against compliance programs that may be insufficient or lack necessary elements to meet expected standards. Sanction checks are a key part of any successful compliance program, and third-party vendors can help ensure they are conducted properly to identify, address, and …



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