Health organizations and the US government are well aware of how important resources are when it comes to providing quality medical care to people. Unfortunately, some individuals or groups take advantage of these resources and use them in an irresponsible manner. Despite being found out and prohibited from taking part of healthcare programs, a number of these excluded individuals still somehow find different ways to work for healthcare organizations.
To protect healthcare organizations from these individuals, the Office of Inspector General (OIG) has created the List of Excluded Individuals/Entities (LEIE). As its name implies, the list includes individuals or entities that are no longer authorized to provide services or supplies to healthcare programs that are funded by the government, most notably Medicare and Medicaid.
Important: The LEIE only prohibits individuals or entities in the list from claiming payment for government-funded healthcare programs. Being included in the list does not exclude individuals or entities from their right to receive benefits from these programs.
Why is LEIE Needed in the First Place?
Without the LEIE, healthcare organizations have no reliable way of determining if an individual or entity is excluded from providing services and supplies to government-funded healthcare programs. Those included in the LEIE have a proven record of fraud, patient abuse or neglect, or substance abuse. The LEIE keeps healthcare organizations from unknowingly hiring said individuals or entities, preventing them from taking advantage of healthcare funds.
While the list will only have the name of the excluded individual, it doesn’t mean that the healthcare organization that employs that individual is in the clear. Contracting or employing the services of an excluded individual or entity can result in heavy penalties. This is why regular sanction screening is an important procedure for all healthcare organizations.
Sanction Screening in a Nutshell
Sanction screening or sanction check is a monthly procedure performed by a healthcare organization’s human resource department or compliance officer. In this procedure, employees are checked to see if they are included in the latest version of the LEIE. Regular sanction screening is required by the OIG and follows strict guidelines to ensure that information regarding each individual is accurate.
Carrying out screenings should be a high priority for any healthcare organization. Failure to screen an individual that happens to be in the LEIE could result to thousands of dollars in monetary losses. This is why healthcare organizations are advised to be meticulous when it comes to their monthly sanction screening.
Fortunately, there are many ways to help ensure the accuracy of a health organization’s sanction screenings. Here are just a few common tips that can help in avoiding penalization related to inadequate screening.
- Use Sanction Screening Technology – By using software designed to automate and enhance the effectiveness of sanction screening, it’s possible for a healthcare organization to perform checks with minimal risks of inaccuracies caused by human error. Advanced sanction screening solutions can automatically send email notification in case it detects any matches with the most recent version of the LEIE. This allows the healthcare organization to address the issue as soon as possible, minimizing the penalties and fines it may cost the company.
- Screen on a Nationwide Scale – Individuals or entities may have already faced disciplinary action before they arrived in the healthcare organization’s area. This means screening on just a state-wide scale may fail to yield an accurate result. At the same time, searching only the federal list without checking state-level lists may cause you to miss individuals and groups that have been excluded by state-level healthcare programs.
- Perform Background Checks – In addition to checking OIG’s exclusion list on a monthly basis, it’s possible to perform background checks on your employees and contractors before hiring them. In fact, a background check that reveals frequent transfers from one employer to another may indicate that an individual is an excluded person. Performing thorough background checks during the hiring process can help filter out excluded persons even before they have the chance to get employed by the healthcare provider.
- Stay Updated – Checking the same version of the LEIE that was used during the last check is basically screening with outdated (and most likely incorrect) data. It is the employer’s responsibility to make sure that sanction screening is done using the most recent version of the LEIE. This is because an excluded individual might have already been cleared in the most recent version of the LEIE. On the other hand, individuals that were not in the LEIE by then might have already been included in the most updated version of the list.
- Screen Everyone – One of the biggest mistakes a healthcare organization can make when performing sanction screening is cutting corners by limiting the check to physicians. As a rule of thumb, any individual who receives any payment that can be billed in whole or in part to government healthcare programs should be screened accordingly.
What To Do When An Employee Is On The List
Employing an individual that is included in the LEIE puts a health organization at risk of facing serious consequences. However, there are ways to minimize the fines and penalties in case you do find an excluded employee. After confirming a match, it’s important to do the following as soon as possible:
One of the first things that healthcare providers must do after finding a match is process the termination of the excluded person. The longer that individual stays employed and the more resources they receive, the bigger the fine will be. Once a match is confirmed, it’s important to determine how much money or items have already been billed to federal healthcare programs because of the excluded individual.
Once enough information has been gathered, the healthcare provider must issue a letter of disclosure to the OIG. It’s also important to contact the excluded person in order to advise them NOT to refer patients to the organization in the future. Last but not least, patients that were involved with the excluded person must be notified accordingly.
It’s the responsibility of organizations and professionals to ensure that resources allocated to providing healthcare are used responsibly. Proper sanction screening not just helps healthcare organizations avoid hefty penalties, it also keeps medical resources safe from fraud and abuse.