Webinar: Sanction Screening Rules, Requirements and Techniques
Webinar Date/Time: September 27, 2011 at 1:00 PM ESTDownload Materials
As a Condition of Participation, healthcare providers must screen against published sanction data all those with whom they engage or have a business relationship. CMS regulations state that “No payment will be made by Medicare, Medicaid, or any of the other federal health care programs for any items or service furnished by an excluded individual or entity….” In 2009 CMS issued a letter to Medicaid directors urging them to require providers to sanction screen employees. They call for states to mandate providers to independently screen against their own Medicaid sanction list as often as monthly. More requirements are expected as a result of the Patient Affordable Care Act (PPACA) and CMS will be coming out with new rules on the subject.
The OIG warn that any claims emanating from a sanctioned individual or entity may be viewed as a false claim. In the last three years alone, the OIG has taken enforcement action in over 60 cases related to employing of or contracting with excluded individuals that resulted in over $10 million in settlements. The OIG is increasing its enforcement interest in this issue and has a number of national initiatives under consideration to identify and recover payments to entities that collected reimbursement from [excluded] employees. The OIG also suggests screening against the General Services Administration (GSA) debarments on their Excluded Parties List System (EPLS). All of this creates new exposure to liability as well as increased costs in time and resources to meet these standards.
During this web conference, we examined the whole issue of sanction screening. This included providing an overview of the Federal and State authorities, processes, and implications related to the exclusion from participation in Federal and State health care programs, as well as recent enforcement initiatives and actions related to sanction screening. Steps were offered to avoid legal and financial exposure related to excluded individuals and entities, as well as guidance to help you manage your sanction screening process. Specific topics included:
- Understanding the exclusion process
- How to mitigate risks through timely sanction screening
- Review of different sanction databases at the Federal and State level
- Increasing efficiency of and reducing cost in sanction screening
- Examples of how to effectively screen against multiple Federal/State databases
Richard Phillip Kusserow
Richard is the CEO of Strategic Management Services, LLC. (SMS), a Virginia-based company that provides consultative services to health care providers on government health programs, and specializing in developing, implementing and measuring effective compliance programs for health care businesses. He is the former DHHS Inspector General for eleven years.
Jillian M. Bower, MPA
Jillian provides regulatory compliance related services, including compliance program implementation and assessment and HIPAA Privacy and Security gap analyses. While working at SMS, Ms. Bower has worked directly with Health Resources and Services Administration on auditing the source data of the HIPDB. As a Senior Associate, she is highly involved with the development and customer support of the Compliance Resource Center, a comprehensive and integrated end-to-end compliance management tool that includes sanction screening services.