Employing a sanctioned individual can lead to steep penalties from the Office of General Inspector (OIG). The penalties can include suspension from government programs like Medicaid, steep fines of up to $10,000 and in extreme cases jail time. As such, it is in the best interests of every healthcare organization to try their best not to fall afoul of the OIG.
However, the risks of employing individuals of a questionable character extend beyond a potential backlash from the OIG. If you end up with a Dr. Tara Knowles (Sons of Anarchy) on your staff, the OIG becomes the least of your worries. The safety of your patents, the security of your equipment and even the wellbeing of your other staff can be in jeopardy.
Basically, it is in your best interest to ensure that you do not hire any individuals who are of questionable character. In the event that you mistakenly hire them, then it is best if you identify them as fast as possible. The only way of achieving this is through thorough healthcare sanctions checking. The ultimate question is: what is the best way to carry out such checks?
Well, effective healthcare sanctions checking has two major aspects. The first is determining where to find out the relevant information about sanctioned individuals. The second is determining how to schedule the checks such that they are as thorough as possible. Let’s examine each of these aspects in detail, beginning with where to find information.
Sources of Sanction Information
The most obvious sources of information are the sanction lists which are periodically released by regulatory authorities. The most obvious list is the List of Excluded Individuals (LEIE) which is published by the OIG. Another is the Excluded Parties List System (EPLS) of the U.S. General Services Administration.
Making sure that you are up-to-date in checking these lists is a minimum requirement for complying with the OIG. At least, it ensures that you will not be caught in violation when the inspectors come calling.
However, although checking for individuals on the EPLS and LEIE is great, it does not constitute the maximum protection. For starters, these lists are updated intermittently. This leaves a gap between the time an individual is sanctioned, and the moment their name appears on the list. As such, by the time you check a name may not be on the list, but then a few days later, upon updating, the name is put on the list.
Secondly, not being on the sanctioned list does not guarantee steadiness of character. The best way to verify someone’s character is to carry out an exhaustive background check. This includes a criminal records check which goes beyond the state where the individual is being hired. Check out the records at the person’s previous work and residential areas. For safety, check out at least the previous 7 years. Only after such a check can you be confident that you’ve carried out the due diligence in ascertaining the person’s track record.
When To Carry Out The Checks
An exhaustive medical sanctions checking program isn’t a one-off event. It is a continuous process which is designed to ensure that no one falls through the cracks. Ultimately, it takes only one mistake for an incident to occur which can cause irreparable damage to your image and reputation. As such, you have to be vigilant. An exhaustive checking program should occur at three stages.
At The Time of Hire
Before you hire someone, you have to carry out a thorough background check on them. This is a standard procedure in almost every organization. As part of the pre-employment screening, background checks are carried out. Basically, before you even think of hiring someone, you need to carry out a thorough check on them.
At The Time of Appointment
Most organizations end at pre-employment background checks. As soon as an individual passes that screening process, they assume it is enough. However, before you give someone an appointment letter or contract, you need to carry out another check. This may seem repetitive, but it is extremely important.
Remember the intermittent nature of sanction lists like the EPLS and LEIE. Between the time you screen a person and the moment you appoint them, their name may have been added on the sanctioned list. To be on the safe side, crosscheck before you put pen to paper.
At Regular Intervals
You need to schedule periodic checks on all your employees. You can schedule this annually, bi-annually or monthly. The frequency is entirely up to you. However, what you need are regular checks. The reason for this is that people change. As such, by the time you hire someone, they may be clean. But then, something can happen and they become compromised. Just like Tara Knowles, they may start out well but then turn into someone else.
Another reason for the regular checks is to stay abreast with the EPLS and LEIE. These lists are updated on a monthly basis. At the least, you need to keep scanning these lists in order to ensure none of your staff is currently on the list. Otherwise, the penalties of being found with a sanctioned individual on your staff will be quite severe.
Ultimately, regular healthcare sanctions checking can enable you to stay within the OIG regulations. It is also the only way of maximizing the safety of your patients, equipment and staff by ensuring that no Tara Knowles exists on your pay roll. Therefore, you need to implement them as a matter of policy.
The best way to ensure regular checks is to centralize all your sanction screening functions. This is especially important if you have a large organization with numerous branches. Sometimes it may be difficult for people at your upcountry branches to keep abreast with the latest screening regulations. If the process is centralized, it can be much easier to ensure that every individual is checked as thoroughly as possible.
In case you feel that you don’t have the capacity to carry out thorough checks (especially the criminal records checks), then hire out the process. There are numerous companies which specialize in carrying out criminal background checks. You can hire them to carry out such checks, while you concentrate on EPLS and LEIE list screening. Having professionals to carry out the background checks can give you the assurance of being as thorough as possible.
In a nutshell, healthcare sanctions checking is a must for every healthcare service provider. It not only ensures that they keep up with OIG regulations, it also protects them against employing individuals who can ultimately destroy their reputation. Therefore, if you are a provider of healthcare services, make sure that you perform these checks at three levels i.e. at the point of hiring, at the point of appointment and on a periodic basis. This will ensure that you have the best employees possible – employees you can confidently entrust with your clients and expensive equipment.
