Implementation of a strong sanction and exclusion screening program is just one of the various tools you rely on to ensure patient safety and program compliance. Further, conducting sanction screening protects your organization from civil monetary penalties. The requirement to check the names of employees, medical providers, and suppliers against the federal OIG and GSA exclusion lists seems pretty straightforward. Yet, you know that just checking the OIG Exclusions List is not enough. When it comes to sanction screening, there are essentially two key components to these emerging standards: frequency and scope.

Frequency - Daniel Levinson, Inspector General of the federal Department of Health and Human Services has already urged healthcare entities to check the federal OIG exclusion list on a monthly basis. And now, the Inspector General's Office of the Texas Health and Human Services Commission has recommended that "all service providers should check OIG's exclusion list monthly." You can read more about their recommendation directly from their website. With Tennessee already announcing a requirement to perform monthly screening, clearly, the trend for state IGs to recommend monthly checks continues.

Scope - Of the 24 states that publish their own exclusion lists, not all report all names to the OIG. This is problematic because the Affordable Care Act of 2010 requires States to terminate a provider or supplier under the Medicaid program when the provider or supplier has been terminated by Medicare or by another State's Medicaid program. So if not all names from all states are reported to the federal exclusion list, just checking the federal OIG is not enough. Lists from all states must be checked.

Obviously, the task of checking the federal OIG and all state lists on a monthly basis can be a burdensome one. If you are a SanctionCheck client, you have the option of running monthly searches to help meet this emerging standard.

About The Office of Inspector General, Texas

The Office of Inspector General works to protect the health and welfare of people in Texas receiving Medicaid and other state benefits. To help protect these recipients, OIG may prevent certain people or businesses from participating as service providers. The people or businesses who are excluded from participating as providers are added to the Texas Exclusions List. Reasons for exclusion may include, but are not limited to:

• A conviction for program-related fraud, or patient abuse
• An adverse action by a licensing board, such as the Texas Board of Nursing, or Texas Medical Board
• Being excluded by from the Medicare program

Website: http://oig.hhsc.state.tx.us/oigportal/

Photo credit: The National Guard