Exclusion Checking: A Critical Necessity
Published Sunday, February 24, 2019
If you accept Medicare and/or Medicaid money, did you know that you are required to check if your employees, volunteers, officers and board members are excluded, disbarred or suspended from participating in government programs? Did you also know you have to perform this check every month?
If you’re surprised after reading this, you’re not alone. Many organizations are unaware of the exclusions check requirement, including how often it needs to be performed. Once learning of the requirement, the next question is usually, “Where can I go to check?”
Given the number of federal and state databases that must be checked, this task can be daunting. That said, the Office of Inspector General, the Office of Medicaid Inspector General, the System for Awards Management, and the Office of Foreign Asset Control are four great places to start. Run the names of your employees, volunteers, officers, and board members against those databases. If you get a match, you may wish to discuss next steps with your HR department or with your counsel. (Checking these databases online may take you a while. Most only allow you to enter one name at a time, so be prepared).
Exclusion, debarment or suspension can happen for a number of reasons, including Medicare or Medicaid fraud convictions, sexual offenses and drug convictions. Lesser known reasons include default on certain types of medical student loans and malpractice issues (for example, you have a physician on your board who has a malpractice action against them).
If you need exclusion list checking services, EF Recovery can help. We’ve partnered with Taiga Compliance to bring their “Taiga Check” screening capabilities to our customers. Performing a check is as easy as uploading a spreadsheet to Taiga’s HIPAA-compliant, secure site. Names are checked against all major databases, with a customized report returned to your department.