The U.S. Department of Health and Human Services Office of Inspector General (OIG) requires that health care providers conduct regular sanctions and exclusion screening of all workforce members, vendors, contractors, new hires, physicians, volunteers etc. to determine if any individuals or entities are excluded from participating in federal health care programs. The sanctions screening process involves collecting names and identifying information from these parties, i.e. first, middle and last names, Social Security Number, date of birth, provider license number etc., and screening them against the names and information of excluded individuals or entities included in state and federal exclusion databases. The most commonly-screened databases include the OIG List of Excluded Individuals and Entities and the General Services Administration System for Award Management. However, organizations should also screen against state Medicaid databases, the Office of Foreign Assets Control Specially Designated Nationals list, the Drug Enforcement Agency Criminal Cases Against Doctors and Administrative Cases Against Doctors lists, the Food and Drug Administration Debarment list, and others, depending on the nature of their service. Individuals or entities listed on any of these federal or state exclusion databases have been involved to some degree in fraud, waste, abuse or other illegal or unethical misconduct and, therefore, should not work at any health care organization or provider.
Identifying and properly addressing excluded individuals and entities is important for health care organizations to ensure the workplace is safe for patients, customers and providers. By conducting ongoing sanctions screening, organizations can reduce the risks of hiring or working with anyone who is excluded, which also reduces instances of fraud, waste, abuse or other unethical behavior that can become liabilities for the organization. Once an organization recognizes the importance of sanctions and exclusion screening on a regular basis, it must decide between conducting screening in-house, outsourcing the screening to an external firm or using a sanctions screening tool.
Challenges of In-House Sanctions Screening
While it may seem easier at first to keep the screening process completely internalized, there are many challenges associated with this option. In order to efficiently screen the names of all new hires and current workforce members, the organization must have effective work flow procedures in place for all stages of the screening and name verification process. The organization must have systemized processes for how to input names and information to initiate the screening process, how to select which databases to screen, how often to screen, etc. It must also have procedures for how to verify the results generated from the screening as non-matches, potential matches or positive matches, and how to follow up on any potential or positive matches of excluded individuals or entities. The organization must be able to effectively track the thousands of names that are being screened while dedicating some of the workforce to manage the input, output, and manipulation of data. Organizations that complete sanctions screening in-house have to complete these tasks while maintaining all regular workplace operations, which may be difficult to balance.
Sanctions screening is a detailed and crucial component for successful compliance operations that must be performed accurately every time. Organizations that conduct sanctions screening completely in-house without utilizing other tools or resources are less likely to complete screening as accurately or frequently as needed to properly ensure all workforce members are free from exclusions. Some organizations may become overwhelmed with the ongoing responsibilities of conducting screening while staying on top of other priorities in the Compliance Department or other areas of the organization.
Utilizing Sanctions Screening Tools
Conducting sanctions screening in-house without using any external tools may be difficult and time-consuming, and it may be too expensive for some organizations to outsource the sanctions screening process. However, there is a middle ground solution that is more cost-effective than outsourcing the whole process and still allows the organization to keep the process internalized without overexerting the workforce. Many firms that specialize in health care compliance offer access to their comprehensive sanctions screening tools. Screening tools, such as highly developed sanctions screening software, enable organizations to conduct screening more easily in-house because it streamlines the screening process through a centralized system that compares the organization’s data with that of federal and state databases. The organization will not need as many workforce members manipulating the input and output of names and data, and will have access to a robust system that manages the data for them. This makes more workforce members available to participate in other compliance-related tasks, such as updating policies or conducting compliance training, while increasing the efficiency of the screening process for those workforce members still responsible for conducting screening.
Sanctions screening tools provide a flexible approach to in-house screening and can improve the accuracy and speed of the process. Screening tools provide additional benefits such as downloadable results and multiple search capabilities that are useful for conducting more comprehensive screening. Sanctions screening tools such as screening software can help organizations regularly screen the names of their workforce members and new hires in-house more efficiently, which limits the amount of workforce members in the organization who have been involved in fraud, waste or abuse and improves overall compliance operations.
Five Key Features of a Sanctions Screening Tool
When searching for the right sanctions screening tool, organizations should choose a tool that improves the efficiency and effectiveness of the sanctions screening process. Workforce members who conduct the screening should have easy access to the tool and the databases that the organization’s names are screened against, as well as comprehensive screening and search options. These features optimize the organization’s screening capabilities and generate reliable, validated results that help reduce the chances of hiring or working with any excluded individuals or entities. Five key features for effective sanctions screening include:
- 24/7 Access: One of the most important benefits of a sanctions screening tool is that it is available for the organization to use at any time of day, on any given day. This allows the organization to conduct sanctions screening at a time most convenient for them and at any frequency, which provides the flexibility to conduct screening around other organizational priorities.
- Multiple Search Options: The tool should offer multiple search options, such as single name search and batch name search, to maximize the organization’s search capabilities. Single name searches are ideal for ad hoc searches or to conduct pre-hire screening, whereas batch name searches are best for monthly screening of names.
- Multiple Exclusion Databases: When conducting sanctions screening, organizations often need to screen individual and entity names against more than one database at a time. The individual or entity may be excluded on multiple databases, so screening them all at once saves the organization time and effort. An effective sanctions screening tool should include multiple exclusion database options that the organization can select every time it conducts a new search.
- Easy-to-Use: The platform or program on which the tool is hosted should be easy to use, and easy to teach to new workforce members. If all levels of the workforce understand and can utilize the sanctions screening tool, then the process is more effective because all parties are comfortable and confident in using the tool.
- Downloadable Results: Conducting the screening search is only one part of the screening process—the organization must also be able to download and export their search results from the tool. This ensures that the organization has the search records for internal filing and future reference if needed.
Sanctions screening is critical to ensure that all individuals and entities associated with the organization are not excluded from participating in federal health care programs. Although organizations can conduct sanctions screening solely through an internal process or outsource the service to a specialized firm, the easiest and most cost-effective option for effective sanctions screening may be to utilize a tool, such as screening software. Screening tools are specifically developed to provide robust screening capabilities that organizations can use as an extension of their own screening processes. Organizations should utilize a screening tool that includes the five key features in order to advance their sanctions screening and improve the organization’s compliance with federal and state regulations.
About the Author
Emily Tait is the Marketing and Proposal Manager at Compliance Resource Center. She has a master’s degree in professional writing from Carnegie Mellon University and has been part of the Compliance Resource Center team since April 2017.
About Compliance Resource Center
Compliance Resource Center has been leading the compliance industry since 2010 with our complete suite of healthcare compliance software and solutions that are geared towards improving compliance program operations. Our solutions ensure that organizations regularly meet federal and state laws and supply the necessary resources to sustain long-term compliance.