SanctionsCheck™ by Crimcheck (NAPBS Accredited) is a comprehensive database which searches and identifies individuals who are excluded from the participation in federal and state healthcare programs, such as Medicare and Medicaid. The United States Department of Health and Human Service Office of inspector General (OIG) guidelines state that health care organizations cannot employ sanctioned or excluded individuals or vendors.
Recent legislation requires monthly sanction checks on existing staff in some states. Our Healthcare Sanctions database search is the preferred method for ensuring your program is in compliance. Many Healthcare providers have multiple locations throughout the United States, making individual site inspections impracticable. Crimcheck can receive your batch transfer data, adjudicating all returned names for you. Our clients include some of the largest Healthcare providers in the nation.
Batch Processing and Adjudication
Not only does a SanctionsCheck™ return all matching records, but our expert staff is trained in adjudicating verifications against your employee and the excluded individual. We also offer large batch processing using ftp or xml large batch record uploads. Our file transfer protocol (ftp) and data transfer methods are HIPAA compliant.
SanctionsCheck™ by Crimcheck streamlines your compliance with Federal and State Medicare and Medicaid payment regulations. Healthcare organizations that fail to conduct thorough and regular reviews for excluded providers risk large financial penalties and revoked billing rights. OIG sanctions and GSA excluded parties list are just a part of the thorough compliance solutions that Crimcheck provides.
Since these databases do not contain the same exclusions and debarments, our solution includes:
(data filtering and scoring methods are available)
More Than 40 Medical Sanctions Lists, Including:
- Federal Health and Human Service List
- SAM Excluded Parties List
- GSA/EPLS database
- Office of Foreign Asset Control
- Specially Designated Nationals List
- 35 state OIG databases
Federal Health and Human Service List
The Department of Health and Human Services (HHS) is the government’s major agency for protecting the health of Americans and offering crucial human services. Crimcheck will check for healthcare sanctioned individuals or entities by any health care licensing board from all 50 states. The report will include the sanction and disciplinary actions.
SAM Excluded Parties List
The System for Award Management (SAM) is a federal government website which consolidates all exclusion records in Central Contractor Registry (CCR)/Federal Agency Registration (FedREg), Online Representations and Certifications Application (ORCA) and EPLS.
SAM not only reports excluded parties, but also reports government awarded contracts and an organization size and ownership list (ORCA).
GSA (General Services Administration) is an independent agency of the U.S. government which manages and supports the basic functioning of federal agencies. The GSA is made up of two major services: the Public Building Service (PBS) and the Federal Acquisition Service (FAS).
EPLS (Excluded Parties List System) is a list of individuals and entities which are excluded from receiving U.S. federal government contracts or federally approved subcontracts from certain types of federal financial and non-financial assistance and benefits.
Office of Foreign Asset Control/Specially Designated Nationals List
The Office of Foreign Assets Control check encompasses economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
In other words, The Office of Foreign Assets Control is part of the U.S. Treasury which concludes whether an entity or individual is allowable to do business with the United States, especially in regards to finances and trade.
OIG List of Excluded Individuals and Entities
The Office of Inspector General (OIG) is a branch of the U.S. Department of Justice. OIG’s List of Excluded Individuals and Entities (LEIE) supplies information regarding individuals and entities who are presently excluded from involvement in Medicare, Medicaid and all other Federal health care programs. This information is given so that providers who bill Federal health care programs do not submit claims for those on the LEIE. The LEIE is updated monthly for the most accurate results.
Being on the list does not exclude an individual’s ability to receive benefits under the Federal health care programs. It only affects the capability to claim payment for services given from these programs. Furthermore, an excluded individual can apply for reinstatement after the terms of their denial have been completed.
OIG sanctioned parties list are available for the following states:
- District of Columbia
- New Jersey
- New York
- South Carolina
- West Virginia
*Please note, those 26 OIG sanctioned parties list are only available in those states, all other states strictly use the federal list. As new states become available as individual lists, Crimcheck will add those to the search list.
Medical Exclusion Reasons
- Conviction of program related crimes (5 years)
- Conviction relating to patient abuse or neglect (5 years)
- Felony conviction relating to health care fraud (5 years)
- Felony conviction relating to controlled substance (5 years)
- Conviction of 2 mandatory offenses (10 years)
- Conviction of 3 or more mandatory offenses (permanent exclusion)
- Misdemeanor conviction relating to health care fraud (3 years)
- Conviction relating to fraud in non-health care programs (3 years)
- Conviction relating to obstruction of an investigation (3 years)
- Misdemeanor conviction relating to controlled substance (3 years)
- License revocation or suspension (no less than the period imposed by the state licensing authority)
- Exclusion or suspension under federal or state health care program (no less than the period imposed by federal or state health care program)
- Claims for excessive charges, unnecessary services or services which fail to meet professionally recognized standards of health care, or failure of an HMO to furnish medically necessary services (1 year)
- Fraud, Kickbacks and other prohibited activities (none)
- Entities controlled by a family or household member of an excluded individual and where there has been a transfer of ownership/control (same length of individual’s exclusion)
- Entities controlled by a sanctioned individual (same length of individual’s exclusion)
- Failure to disclose required information, supply requested information on subcontractors and suppliers; or supply payment information (none)
- Failure to grant immediate access (none)
- Failure to take corrective action (none)
- Default on health education loan or scholarship obligations (until default has been cured or obligations have been resolved to Public Health Service’s satisfaction)
- Individuals controlling a sanctioned entity (same period as entity)
- Making false statement or misrepresentations of material fact (none)
- Failure to meet statutory obligations of practitioners and providers to provide medically necessary services meeting professionally recognized standards of health care (1 year)
For a list of all exclusion reasons including their corresponding codes, please visit the OIG and HHS website.
Related Public Laws and Acts
Health Insurance Portability and Accountability Act (HIPAA)- Protects health insurance coverage for workers and their families when they change or lose their jobs.
Patient Protection and Affordable Care Act – Commonly referred to as Obamacare, it is a federal statute which goals include minimizing the number of uninsured Americans and reducing the costs of healthcare.
Terms to Know
Employee: Person submitted by client to be searched
Excluded Individual: Person appearing on the federal or state debarred list
False Name Match: A match between the employee and excluded individual that does not actually constitute a match (Example: last name LEE matching last name GREENLEE)
Name Match: A match between the employee and excluded individual of two or more names
Date of Exclusion/DOB Discrepancy: When an employee is cleared form a name match because they were under the age of 18 at the time of exclusion
Debarment: To exclude or forbid an individual or entity from doing something, having certain possessions, rights or practices
Sanction: Punishment for the noncompliance of a law or decree.