Exclusions and Sanctions List Screening Policy

Purpose

This policy explains how Your Business makes sure that no one who works for it or contracts with it is excluded, debarred or suspended from federal or state health care programs or from federal contracts and grants.

Federal health care programs, including Medicare and Medicaid, will not pay for any item or service furnished, ordered or prescribed by an excluded person. OIG treats this as including administrative and management work that supports those services, such as billing, scheduling and supervision (42 CFR 1001.1901; OIG Special Advisory Bulletin on the Effect of Exclusion, May 2013). An organization that employs or contracts with an excluded person can be required to repay the claims involved and can face civil money penalties for each item or service (42 U.S.C. 1320a-7a(a)(6)).

Who Is Screened

Your Business screens the following people and organizations:

• All employees, full-time, part-time, temporary and per diem
• Owners with a 5% or greater direct or indirect interest, officers and agents
• Board members or directors
• Managing employees (anyone who runs day-to-day operations, such as an administrator or office manager)
• Independent contractors and subcontractors who provide or support services, including staffing-agency workers
• Vendors that bill, code, schedule or handle records for us

Conditions of employment and contracts

These rules apply to everyone screened under this policy:

• Passing exclusion screening, before starting and every month after that, is a condition of employment and of every contract with Your Business. Offers of employment and contracts will say so.
• Your Business will not employ or contract with an individual or organization that refuses to give the information needed for screening, and may end the relationship with anyone who later refuses.
• Your Business will not employ or do business with individuals or organizations convicted of health care fraud, or of any other offense that allows a federal or state agency to exclude, debar or suspend them from federal or state programs.

Lists Checked and How Often

Your Business checks every person and organization named above before they are hired, appointed or contracted, and again every month after that, against these lists:

• The HHS Office of Inspector General List of Excluded Individuals/Entities (LEIE), at exclusions.oig.hhs.gov.
• The exclusion records in the federal System for Award Management (SAM.gov).

Your Business also checks: The Medicaid exclusion list of every other state where we provide services

Each check uses the most recent version of each list. Individuals are searched under their current name and every prior or alternate name, including maiden names. Organizations are searched under their legal name, every trade name and the names of their owners.