If you’re working in the field of healthcare compliance, no topic is more important than the Office of the Inspector General’s exclusion list, or the List of Excluded Individuals and Entities. This regularly updated list keeps track of people or companies that are forbidden from being paid under the federal health systems, and health organizations should conduct monthly screening in order to make sure they’re not hiring or contracting with these individuals. Here’s a rundown of the most common mistakes made regarding exclusion screening:
- Not Screening at All
Given the time and expense associated with screening for excluded individuals, it can be tempting to use hire on the honor system and hope you don’t get audited. But this is too great a risk to take. The liability should you hire or contract with an excluded party rests on your organization, and that could result in monetary penalties and even a spot on the exclusion list.
- Not Accounting for Changes
When you’re using the exclusion database, it’s important to account for name spelling differences, since it’s easy for a one-letter change to occur at some point along the line. You should also check for changed names and similar issues.
- Not Confirming Matches
While checking names is important, it’s also necessary to confirm potential matches. The federal exclusion list may not give you enough information up front to be sure that the John Smith you’re considering is the same John Smith who’s been excluded, so further investigation should take place when there are name matches.
- Not Reporting Matches
If you do discover you’ve hired someone on the exclusion list, the worst thing you can do is just keep that information to yourself. Self-reporting to the OIG gives you the opportunity to avoid further penalties.
- Not Considering Outsourcing
If your organization is large enough to have quite a few employees but too small for a large in-house team, exclusion screening can be quite a hassle. And even if your organization can support such a team, it’s still expensive. For that reason, getting exclusion screening software or outsourcing the verification process altogether can be a smart business decision.
What other mistakes should someone responsible for healthcare compliance avoid? Discuss in the comments.
