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Sanctions and Exclusions
Providers, employees, contractors, and vendors form the backbone of most healthcare businesses. Unfortunately, in today’s complicated healthcare business environment, these same individuals also represent significant risk. Healthcare organizations are prohibited from hiring people and companies that appear on federal and state Sanctions and Exclusions lists and the cost of non-compliance is severe, $11K fine per bill involving a sanctioned or excluded provider or vendor.
Compliance is not a one-time event. Some companies occasionally check for integrity exceptions, perhaps monthly, quarterly, or even annually, but these timeframes are insufficient to avoid significant fines and reputational damage. The good news is that ongoing integrity compliance can easily be automated and brought inhouse.
Office of Inspector General (OIG)
OIG is ramping up enforcement activities to eliminate fraud and remove unscrupulous providers and vendors. Working with excluded or sanctioned entities can cost a healthcare organization millions of dollars, money that is scarce in an industry hard hit by the pandemic. Protecting against OIG and state penalties requires:
1. A core understanding of Sanctions and Exclusions screening compliance
– Healthcare providers are expected to screen all employees, contractors, and vendors on a regular basis
– Any organization that works with excluded providers is subject to significant fines and penalties
2. Successful implementation of a detailed Sanctions and Exclusions screening compliance plan
– Put a rigid screening process in place with complete oversight
– Understand and overcome common challenges
3. Commitment to operational compliance screening excellence
– Consider replacing outsourcing with an inhouse technology solution
– 100% real-time checks on a total monitoring list versus prioritizing providers and risk-stratifying remediation efforts
– Adopt next-generation, data-driven technology solutions