Many healthcare providers are currently working with vendors or employees that presents an immediate compliance risk – and they don’t even realize it. Why? These individuals or organizations may be featured on exclusion and/or sanction lists, and organizations have a legal obligation to identify and remove them. 

But with so many different lists to consider, how do providers do that in an efficient and accurate manner?  

The answer is healthcare sanction screening – and this article provides everything you need to know about the subject. 

What is Healthcare Sanction Screening? 

Numerous individuals and entities are excluded annually from participation in government-financed healthcare programs. Both the federal and state authorities maintain lists of those not permitted to participate in programs financed by government authorities. For example, the Department of Health and Human Services Office of Inspector General maintains the List of Excluded Individuals and Entities (LEIE). 

The process of vetting individuals and organizations to ensure they are not included on these lists is known as a healthcare sanction screening. This can be done either manually or using automated software, but the fundamental principle is the same: an individual’s name is cross-referenced against all available exclusion lists. The process should then be documented, with a clear list of the individual and all lists that were inspected. 

Why is Healthcare Sanction Screening Important? 

Regular sanction screening is vital for several reasons: 

• Compliance: Organizations are bound by both federal and state regulations to avoid working with individuals on exclusion lists. S 
• Access to Funding: Engaging parties that are featured on exclusion lists violates conditions of participation in Medicare/Medicaid, and any claims submitted that include the involvement of such individuals may be considered false or fraudulent.  
• Financial Penalties: A failure to adequately vet your vendors can result in large financial penalties and reputational damage. 

What Are the Benefits of Healthcare Sanction Screening? 

Screenings help healthcare entities identify and prevent the engagement of individuals or entities that have been excluded. The benefits of this are numerous: 

• Compliance with federal and state regulations 
• Avoiding violating conditions of participation in government-financed healthcare programs  
• Protecting patients by avoiding those who may have been involved in abusing/neglecting patients, stealing drugs/equipment, selling, or seriously mishandling patient information 
• Helping to ensure potentially dangerous people don’t have access to patients or their records 
• Mitigating the risks of costly fines and penalties 
• Protecting an organization’s reputation and community standing 
• Avoiding government-imposed fines and penalties 
• Preventing legal and civil suits resulting from retaining a sanctioned individual or organization  

Why is Sanction Screening So Complex? 

Sanction screening is complicated by the fact that there are many federal and state exclusion and sanction databases, including but not limited to:  

• OIG LEIE 
• State Medicaid Exclusion Listings 
• General Services Administration System Database for Award Management (Debarments) 
• FDA Debarment List 
• Office of Foreign Asset Control (OFAC) 
• Drug Enforcement Agency (DEA) Administrative Action List 
• CMS Preclusion List 

Checking so many different databases has its challenges, in that databases use different identifiers; many do not permit batch searching as doing it one name at a time is time-consuming; and investigating/resolving potential name matches with a unique identifier is difficult when different government entities use other identifiers. The result is that conducting individual searches of large worker populations can be an arduous and time-consuming task for compliance, risk mitigation, and human resource professionals. 

For these reasons, the vast majority of healthcare organizations use a vendor that provides a tool with which all the needed federal and state databases can be batch-searched easily. Vendors are also available to have their experts conduct the screening, investigating, and resolving of the results at a fraction of the cost of doing this work in-house.

How Often Should a Supplier Be Sanction Checked? 

Healthcare sanction screenings should be undertaken monthly to ensure issues are caught before they cause compliance issues. Suppliers can be added to exclusion lists at any time, and working with them will immediately present a risk to your organization. But most organizations struggle to undertake this volume of screenings using manual methods. 

Interested in learning more about Sanction Screening? Contact Shelby Cole at [email protected]. 

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