The OIG 2015 Work Plan: 4 Background Check Implications for Healthcare Organizations
It’s that time of the year again and I don’t necessarily mean it due to the upcoming holiday season. On October 31st, the U.S. Department of Health and Human Services released its Work Plan for the fiscal year 2015, which summarizes new and ongoing reviews and activities the Office of Inspector General (OIG) will pursue in the coming year and beyond. As a healthcare background screening firm, I thought I would highlight four key areas from the 2015 Work Plan that contain background check-related implications for healthcare organizations. Here are four areas where you might want to review your organization’s background screening practices to ensure it meets the OIG’s latest recommendations.
Assessment of Medical Staff Services Privileging Programs
In the 2015 Work Plan, the OIG stated they “will determine how hospitals assess medical staff candidates before granting initial privileges, including verification of credentials and review of the National Practitioner Databank.” The document also suggests that robust hospital privileging programs contribute to patient safety. With increased oversight in how hospitals screen physicians, medical staff services departments can benefit from enhancing their credentialing process by incorporating components such as criminal background checks, which can help mitigate risk and safeguard patients and staff. Not all state medical boards have the authority to conduct background checks on physicians upon licensure, so having a physician background screening program is one way to ensure to prevent candidates from “slipping through the cracks.”
Oversight of Adverse Events in Inpatient Rehabilitation, Long-term Care Facilities and Nursing Homes
Similar to what was included in the 2014 Work Plan, the OIG will continue to focus on investigating the adverse events that occur in both inpatient rehabilitation and long-term care facilities. They will estimate the national rate of adverse and temporary harm events for Medicare beneficiaries in both long-term care hospitals and inpatient rehabilitation facilities while also determining which events are preventable and their associated costs to Medicare. They will also focus on investigating whether nursing home patients are hospitalized as a result of preventable adverse events. The OIG also stated they will work on providing Congress a report evaluating the implementation of the national background check program for long-term care employees as required by section 6201 of the Patient Protection and Affordable Care Act (ACA). In these facilities where the OIG has found a significant rate of adverse events, background checks can help as a tool to mitigate risk and protect the care of patients.
Investigation of Employment of Individuals with Criminal Convictions in Home Health Agencies
In 2015 and beyond, the OIG stated they would focus on determining the extent to which home health agencies employed individuals with criminal convictions. This will also include assessing whether selected employees have potentially disqualifying criminal convictions. As a result, it’s important that home healthcare entities review their State and local laws as most States have laws prohibiting certain healthcare-related organizations from employing individuals with certain types of criminal convictions. For home healthcare agencies, specifically, having a continual background screening program in place could be beneficial to ensure ongoing compliance with local and State laws. A background check represents a snap shot in time, so it’s important to have a program in place that has an ongoing monitoring component.
Providers Terminated by One State Should be Terminated in All Others
Although not a new requirement by any means, the OIG stated it will focus on reviewing whether States are complying with a 2011 requirement of section 6501 of the ACA that calls for the termination of Medicaid program providers that been terminated under Medicare or by another State Medicaid program. In the coming year, they will work on assessing the status of CMS’ information-sharing system to determine whether States are sharing complete and accurate information. Although not a direct requirement for healthcare organizations, it’s a clear reminder that checking the OIG’s List of Excluded Individuals and Entities (LEIE) is not enough when it comes to exclusion screening best practices. In order to comply with the aforementioned ACA requirement, it’s important to also screen all publicly available State Medicaid exclusion lists to ensure you don’t have excluded providers in other States (and, therefore, excluded in all) on your staff.
With a commitment to quality of care, the OIG 2015 Work Plan has several components where healthcare organizations can benefit from a proactive background screening program. Click here to download the full 2015 Work Plan.