Exclusion Screening

In case you may have missed it, the Office of Inspector General (OIG) published its latest Work Plan for fiscal year 2016 last week. Each year, healthcare organizations should review their compliance programs to ensure they address the regulatory agency’s latest areas of focus.

The Department of Health and Human Services (DHHS) Office of Inspector General (OIG) recently released a report determining whether Medicaid providers that States reported as having been terminated for cause continued to participate in Medicaid in other States. The study follows last year’s report recommending improvements to CMS’s process for sharing termination information among the States.

While hospitals and other healthcare organizations generally aren’t required to run time-of-hire or ongoing background checks, they often do as part of their voluntary due diligence procedures and to mitigate their liability risk. Some states do require background checks for candidates for certain healthcare positions, but organizations typically run them on all staff members.

As we observe Patient Safety Awareness Week at PreCheck, I thought I would discuss the important role that an effective background screening process plays in patient care and safety. During this time, background checks may be overlooked as a patient safety initiative, but they play a key role in safeguarding both patients and healthcare organizations from harm.

Although there are currently no bylaws instating the requirement of exclusion checks, the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) mandates employers to know the exclusion status of their employees and contractors during their entire lifecycle with the company. According to the OIG, there are over 66,000 healthcare providers that are currently excluded from all federal healthcare programs.

Most employers conduct background checks before hiring a new employee, but it’s a different picture for current employees. While post-hire background checks may not be the norm across industries, there are a few key reasons why a heavily regulated industry such as healthcare might choose to adopt this practice. Pre-employment background checks can mitigate risk during the hiring process, but with patient and staff safety at stake, it’s important to keep healthcare organizations safe in the long-term.

The Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) contains over 66,000 healthcare providers that are currently excluded from all federal healthcare programs. Any healthcare organization that hires an individual or entity on the LEIE can be subject to civil monetary penalties (CMP).

Yesterday, we discussed what healthcare human resources professionals should consider in order to comply with the Patient Protection and Affordable Care Act’s (PPACA) upcoming deadlines in 2015. HR leaders, however, are not the only ones who should be concerned with the implications of PPACA. Although not new for 2015, PPACA contains numerous provisions that expand the U.S Department of Health and Human Services (HHS) and the Office of Inspector General’s (OIG) authority to pursue allegations of healthcare noncompliance.

There’s been no shortage of stories regarding home healthcare background screening practices in recent years. In fact, here are three noteworthy developments from 2014 alone. As we approach 2015, now may be an opportune time to review your organization’s background screening policies.