Health Sanctions Search

VICTIG Healthcare Sanction Checks

The well-being of a healthcare facility hinges upon the quality of its employees. When hiring people to handle matters of life and death, organizations within the healthcare industry must be especially selective — and medical sanctions searches are some of the most important checks to remember to ensure regulatory compliance and high-caliber staff members. This article will discuss what healthcare sanctions searches are, why they’re important, and how you can maintain compliance within your healthcare clinic.

What Is a Health Care Sanctions Search?

A health sanctions search checks whether a person has been excluded, debarred or disciplined by a government agency or licensing body in a way that bars them from healthcare work. The core source is the HHS Office of Inspector General’s List of Excluded Individuals/Entities (LEIE). Federal healthcare programs, including Medicare and Medicaid, won’t pay for items or services that an excluded person furnishes, orders or prescribes.

VICTIG’s health sanctions search draws on 213 federal and state databases, including the OIG LEIE and SAM.gov, with state-level searches across many of them. Most clients run the most comprehensive search level on new hires, then use a standard OIG search for later rescreening. Results show the agency that took the action, the type of action, its dates and its status.

Any employer that bills Medicare, Medicaid or another federal healthcare program, directly or indirectly, needs this screening. That includes hospitals, clinics, home health agencies, long-term care facilities, pharmacies and staffing firms that place healthcare workers. The risk isn’t limited to clinicians. The OIG has said an excluded person can’t be paid with federal program funds even in administrative or support roles.

How Long Does the OIG Employment Ban Remain in Effect?

People don’t usually stay on the medical sanctions list forever; the amount of time an individual’s name remains on the list depends on the severity of the offense. For example, some criminal convictions are tied to 10-year durations while others may be much shorter. In other cases, exclusions may be imposed indefinitely, such as those from licensing boards. The OIG is required by law to impose a minimum of a five-year exclusion for patient abuse, fraud, illegal prescription of controlled substances, and other program-related crimes.

If a person’s medical license has been revoked and subsequently restored, they can request that their name be removed from the list upon the reinstatement of their license. This does not happen automatically, however; the individual must formally request it.

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Why Is It Important to Conduct Healthcare Sanction Screening?

1. To protect patients, staff members, and your organizational health as a whole

Health care centers rely on word-of-mouth referrals and positive public perception to survive. Fraud and abuse are serious offenses that have the potential to ruin the reputation of a healthcare organization. A person may be added to the LEIE for the following types of convictions and felony crimes:

  • Patient neglect, abuse, or medical misconduct
  • Financial mismanagement
  • Theft of medical equipment or medicine
  • Medicare/Medicaid or other health care-related fraud
  • Illegal prescription or distribution of controlled substances

2. To avoid OIG-imposed fines for inadvertently hiring sanctioned persons

Failing to conduct a thorough health care sanction check can lead to a mishire. An employer that knows or should know a worker is excluded can face civil monetary penalties for each item or service that person provides, an assessment of up to three times the amount claimed, and its own exclusion from federal programs.

3. To ensure future eligibility for federal benefits and programs

Federal programs like Medicare and Medicaid ensure that hospitals still get paid for caring for patients who have no private insurance coverage. Without these programs, hospital staff goes uncompensated for care rendered to people who cannot pay. If you want to ensure your eligibility for government-sponsored insurance, you must be diligent in your hiring process. Otherwise, you could hire an excluded individual and disqualify yourself from these federal programs.

How to Remain Compliant With Health Care Regulations

Federal regulations seem to change constantly, which makes it difficult to stay in compliance with health care industry requirements.

Below are some simple ways you can protect yourself from costly liabilities:

  • Screen candidates against the LEIE at hire, then rescreen current staff monthly. The OIG updates the list by the 10th of each month.
  • Make health care sanctions checks a routine part of your background checks.
  • Hire only those who are currently qualified for the work they will be doing.
  • Set up monthly batch rescreening of current employees across departments and facilities so new exclusions don’t go unnoticed.
  • Partner with a third-party background screening service for the most up-to-date screening capabilities and eliminate the hassle.

Why Choose VICTIG for Health Sanction Checks?

A name match on its own isn’t proof. The OIG says employers must verify an LEIE hit with the person’s identifiers, such as an SSN, before acting on it. Common names produce false matches, and treating one as a real exclusion can delay or wrongly block a good hire.

  • Most results are instant. When a possible match needs manual review, turnaround is typically within 24 hours, and most are done the same day.
  • Our team checks every possible match by hand in the source database. OIG matches are confirmed with name, date of birth and SSN. SAM.gov matches are confirmed with name and address.
  • Reports show the agency, action type, dates and status, along with supporting documents and a link to where the record was found.
  • Monthly batch rescreening of current staff is available, so new exclusions don’t go unnoticed.
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