background screening: healthcare screening expanded and explained

Copyright © 2015 TRAK-1 Technology, Inc. All Rights

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The Basic Truths About Background Screening,

Part 17


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Part 17

The Basic Truths About Background Screening:

HealthCare Screening - Expanded and

Explained


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Part 17

Your Host: Rick Coltman

Director of Strategic Marketing and Alliances,

Trak-1 Technology, Inc.

• Please Post Any Questions or Comments You Have in the Comments

Section.

• Want Further Information or Have Additional Questions? Contact Trak-1 at

[email protected]

• Hopefully You Find this Webinar Informative! Please Join Us for Each

Webinar at http://trak-1.com/webinar

Your Presenter: Nancy Roberts,

Esq.

Owner/COO

mailto:[email protected]

http://trak-1.com/webinar


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Part 17

Recipients of Government Funds

OVERVIEW CONCEPT

Must Be Eligible To Receive Those Funds

(I.E. Not Excluded From The Government

Contracting And Reimbursement Programs)


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Part 17

What Does That Mean In The Context Of

Healthcare Entities And Professionals?

- Participate In Any Reimbursement Programs (Federal Or State)

- Must Look At The Rules Associated With Those Government Programs


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Part 17

TYPICAL HEALTHCARE

SCREENING PACKAGE

SSN Trace Address History

Criminal Screening

Civil Screening Exclusion ScreeningEducation And Credentials

Verification

Personal ReferencesState Level Fingerprint Search

(Where Required)


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Part 17

What Are the Benefits of Quality Screening?

• Satisfy Regulatory Requirements

• Determine Reimbursement Eligibility

• Reduce Or Mitigate Risk

• Protect A Healthcare Provider’s Reputation


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Part 17

There Are Many Specialized Searches That The

Healthcare Industry Must Take Into Account

In Addition To The Standard Identity And Criminal

Record Searches…


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Part 17

Office of Inspector General (OIG)’s LEIE

• Excludes Recipients From Federally Funded Health Care Programs

• Maintains The List Of Excluded Individuals And Entities (LEIE).

• Anyone Who Hires from the LEIE May Be Subject To Civil Monetary Penalties

(CMP).

• Reasons For Exclusion Can Include Convictions For Medicare, Medicaid Fraud,

Patient Abuse, Felony Convictions For Financial and Drug Misconduct

• Reports From This Search Include Recipients on the LEIE

This Search Is A Necessity For Any Provider

Rendering Services Directly Or Indirectly And Payable

In Whole Or In Part By A Federal Health Care Program.


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Part 17

• Formerly managed by General Services

Administration

- GSA’s Excluded Parties List System (EPLS)

• Now “ The System For Award Management” (SAM)

- A Portal For The Federal Procurement System.

• Reports Identify Parties Barred From Receiving

Federal Contracts, Including Healthcare Program

Funding Or Reimbursement, And From Certain Types

Of Federal Financial And Non-financial Assistance

And Benefits.

System for Award Management (SAM)


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Part 17

Reports From This Search Include Information On Disciplinary Actions Such As Debarments, Exclusions,

Probation Periods, And Letters Of Reprimand

FACIS (Fraud and Abuse Control Information System)

This Search Has Three Levels


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Part 17

Search Pulls Information From The List Of Excluded Individuals And

Entities

Includes Information From The Exclusion List Managed By The System

For Award Management

FACIS (Fraud and Abuse Control Information System) Level

Must add a State Exclusion Search to

this search to satisfy OIG Exclusion

Screening Requirements


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Part 17

Search combines all of the information

contained in the Level 1 search and

includes sources from one individual

state.


Level 2

This search satisfies the OIG Exclusion

Search if your candidate has only ever

lived and worked in one single state.


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Part 17

• Search Combines All Of The Information Contained In The Level 1 Search

And Includes A Search Of The Disciplinary Action Information From Multiple

Agencies As Well As Those Taken By Licensing And Certification Agencies In

All 50 States.

• This Level 3 FACIS Search is what we recommend to our healthcare clients

and is the most commonly used

• Examples of Who Uses: Pharmaceutical Companies, Hospitals, Home

Health Systems And Insurers.


Level 3


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Part 17

A Real Life Example

- A Drug Manufacturer Working With The FDA To Prove The Safety And Effectiveness Of A New Drug

- Seeking To Hire A New Clinical Investigator- The Company Would Perform A FACIS Search On

The Applicant To Make Sure He Or She Had Not Been Sanctioned For Submitting False Information To The FDA.


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Part 17

Providers Of Certain Healthcare Services Are Required To Be Licensed Practitioners.

Recurrent Verification is Required to Ensure Ongoing Maintenance of Proper Credentialing at Your organization

Applies to: Drivers, Certified or Licensed Healthcare Workers, attorneys, CPA level workers, etc.

Professional License Verification

Ensuring That Your Providers Have The

Proper Credentials Can Mitigate YOUR

Risk


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Part 17

2015 is a Great Time To• Re-assess The Scope Of Your Exclusion Screening

Practices

• Expand The Scope Of Your Exclusion Screening

Practices

• Re-assess The Frequency Of Your Screening

• Re-assess The Individuals You Are Choosing To

Subject To Exclusionary Screening


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Part 17

What’s the risk?

• The Low-level Consequences Of Failing To Comply Can Be Fatal To

Even a Healthy Ongoing Health Care Concern.

• Cost of undergoing a review, audit and repair is extraordinary

• Imposition Of Civil Monetary Penalties Costly- Fine of up To $10,000 For Each Item or Service Furnished By an Excluded Person

- Plus Penalty Assessment of Up To 3X The Amount Claimed

• The Most Serious Cases Result in Total Entity Exclusion


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Part 17

WHY DID HEALTHCARE ENTITIES

“RE-WRITE” THEIR EXCLUSIONARY

SCREENING PRACTICES IN 2013-

14?


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Part 17

BECAUSE The 2013 Bulletin Addressed The Impact

Of The Affordable Care Act Of 2010

• Directly Extended Civil Monetary Penalty Liability

Exposure Not Only To Employees And Contractors,

But Also To Other Practitioners And Individuals

Who Deliver Items And Services Covered By The

Excluded Provider.

• Pharmacists, Transportation Service Providers,

Administrative And Management Service Professionals

Are All Examples Of Individuals Who Should Also Be

Screened For Exclusion From Participation.

Department of

Health and

Human

ServicesOffice of Inspector

General


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Part 17

Relying on a Third Party (Such as a

Staffing Firm) To Screen For These Items

is Not in and of Itself a Defense For a Health Care Entity.

The 2013 Bulletin Additionally Outlines That…


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Part 17

• It Can Demonstrate That It Reasonably Relied On The Staffing Agency To

Conduct Exclusion Checks By Requiring Them To Specifically Be Included

In The Terms Of The Staffing Contract.

• Proof That The Firm Is Conducting These Checks Should Be Regularly

Obtained Prior To A Placement Of The Individual With The Health Care

Entity In Question.

• Annual Checks Are The Preferred Frequency Indicated By The OIG’s

Terms In Their Recent Integrity Agreements (note: The OIG Bulletin Only

Specifically Indicates That “Regular” Checks Are Necessary)

The Provider May Reduce Or Eliminate CMP Liability If…


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Part 17

It Is Important To Have A Full

Understanding Of What You Are Getting

In Determining The Scope Of Exclusionary Screening

You and/or Your Screening Company Of Choice Are Doing…


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• Search The OIG’s List Of Excluded Individuals And

Entities (LEIE) With Current And All Known Names.

• Verify Search Results Using Name, Location And

SSN Or EIN Information To Reduce Name-match

Only Results.

• The OIG 2013 Bulletin Recommends That Providers

Rely On The LEIE Instead of SAM, The National

Practitioner Data Bank, Or The Health Care Integrity

Protection Databank.

Your Screening Company Should…


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Part 17

• Check Applicable State Exclusion Databases In The

States Where The Individual Has Been Or Is

Licensed To Practice.

• In The Case Of A Non-licensed Practitioner, This

Means That Conducting A State Exclusion Database

Search In The States Where The Individual Has

Previously Resided And Worked Is Recommended

By The OIG.

However, Providers Should Go Further Than Just Checking The OIG’s LEIE…


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Part 17

Some States Require Exclusion Checks More

Frequently Than The OIG Suggested Annual

Check

Important Note…

So Being Aware Of Your State’s Requirements

And Expanding Your Screening Practices To

Satisfy Them Is a Part Of Your Obligation.


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Part 17

Take Away Points– Understand The Role Of The Office Of The Inspector General

– Understand The Role Of The System For Award Management

– Understand The Role Of FACIS (Fraud And Abuse Control Information System)

– Understand The Purpose of the Professional License Verification

– 2015 Is A Great Time To Audit Your 2013-14 Changed Screening Practices.

– There Are Hefty Consequences If You Don’t Reassess Your Screening Practices.

– Know How The 2013 Bulletin Addressed The Impact Of The Affordable Care Act Of 2010.

– Know How A Provider May Reduce Or Eliminate CMP Liability.

– Know How To Determine The Scope Of Exclusionary Screening You and/or Your Screening

Company Of Choice Are Doing.

– Know What Your Screening Company Should Be Doing And What Precautions You Need To Take

For Your Particular State.


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Part 17

Coming Up Next…

The Trouble With Pointed Fingers

in Police Records

Copyright © 2015. Trak-1. Technology, Inc. All Rights Reserved.

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