5 Exclusion Screening Best Practices for Healthcare Compliance
Healthcare exclusion screening can be seen as one of the most complex and challenging areas of compliance. It’s one that demands your time, attention, and most importantly, due diligence to ensure you’re not working with excluded or sanctioned individuals. With the Office of Inspector General (OIG) increasing enforcement efforts regarding exclusions, healthcare organizations that employ excluded individuals or entities are subjected to costly fines from the federal government.
As you review your current exclusion screening process and policies, here are five practices you should consider to ensure you remain in good standing with the OIG.
1. Determine Sources to Screen
You should first consult with legal counsel when determining which databases are required to screen—based on distinctive circumstances, regulations your facility needs to follow, and any other screening requirements. “I highly recommend working with legal counsel on that as the requirements can significantly change from state to state—and even from one regulator to another,” says Cristina Loayza, Product Manager for SanctionCheck, PreCheck’s ongoing exclusion screening solution.
Once you’ve identified which sources you need to check, the next step is to know your sources and have a written procedure for each source. For example, you may want to include:
- How you check the names in your list against the sources;
- What kinds of identifiers are needed to confirm the name matches;
- And who to contact in case there are name matches that you can’t resolve.
2. Conduct Searches Pre- & Post-Hire
The point of exclusion screening is to minimize risks such as civil monetary penalties (CMPs); therefore, it’s important to consider screening your employee, medical staff, and vendor population as often as you can in order to have the least amount of exposure possible, Loayza says. The frequency at which screening needs to take place differs from state to state, though many exclusion authorities, including the OIG, update every month. With this, monthly screens are considered to be best practice for exclusion screens.
3. Search Name Variations
In addition to the name you call your employee, you must also look through aliases and other possible name variations. If you know of an alias name for your employee, you’ll need to search that as well, Loayza advises. “You may also consider switching the first and last names during your search to see if you come across a name match—or even searching each last name for those with hyphenated names. The goal is to cast a wide net in order to catch as many names as possible that the individual may have used.”
4. Review Name Matches Thoroughly
Common names such as Robert Smith quite often return with multiple possible name matches from different sources. You must thoroughly review each of these hits because they won’t all refer to the same person. Some advice: establish a good process to handle these types of situations. “This becomes very helpful when a good amount of name matches come back,” Loayza says. It will ensure you performed your due diligence in searching all required databases.
5. Document, Document, Document
There will be moments of doubt when the lack of identifiers leaves you questioning whether or not the name on the excluded list is in fact your employee, medical staff member, or vendor. Even when you reach out to the data source, they may not respond immediately, Loayza says. “This is why it’s important to have great documentation in your process, and the necessary steps needed to clear name matches. Especially in the event of an audit, you’ll need to prove that you did everything that you could to not hire an excluded individual. Screen shots, time stamps, and process documentation will all go a long way.”
If you discover you’ve hired or are currently working with a sanctioned, terminated or debarred individual, you must notify your legal counsel immediately. You’ll need to follow reporting guidelines, which may differ by state. You’ll also need to consider going through the OIG Self-Disclosure Protocol, where facilities can self-report to the OIG that they did in fact violate the exclusion mandate. While this does not exempt your facility from any liability, the outcome is generally considered to be more favorable than getting fined through an OIG investigation, Loayza says.
When was the last time you reviewed your current exclusion screening policy? Contact us to learn how PreCheck can help you streamline your exclusion screening process.