According to the Federal Sentencing Guidelines, an organization “must have established compliance standards and procedures to be followed by its employees and other agents that are reasonably capable of reducing the prospect of criminal conduct”. The OIG has published numerous Compliance Program Guidances for health care institutions, instructing them on how to establish robust compliance programs including advice for sanction screening and reporting.
As a third party administrator, OIGCN can assist health care institutions in building a robust sanction screening, validation and reporting program that aligns with federal/OIG and state regulations/guidelines, protects patients, prevents fraud, and promotes organizational integrity.
The steps we undertake are as follows:
Assessment of Client Program Set-up
In order to ensure a smooth implementation of the screening program, we first assess the health care institution’s current set-up for screening, including policies/documentation, IT system set-up, vendor relationships, and reporting mechanisms.
Data Gathering & Screening – Employees, Physicians and Vendors
Our IT department works together with the health care client’s IT group to arrange for the gathering and organization of employee and associate (physicians, referral sources, volunteers, etc) data files to be used during the screening process. We assist health care clients in preparing a Vendor Compliance Letter to inform vendors of the new compliance screening requirements, and then we work directly with vendors individually to gather their data files and perform their screenings. Also, we partner with health care institutions individually to examine any anticipated problems or concerns with rolling out the program to physician practices and vendor groups.
The most important part of the screening program is VALIDATION, where we verify the identity of any sanctioned names that result from the screening process. Our trained investigators speak directly with Federal and State agency officials to perform the validation process. No HR actions can be taken by a client unless sanctioned results are first validated.
Documentation and Results Reporting
Each client will receive a phone call about any sanctioned names that are validated by us. Also, the client will receive a comprehensive report that provides statistics on the number of names screened and a summary of the results. Clients will also receive a report about screening results of each of their vendors, including any validated sanctions. Documentation is stored on our secure server for 5 years. Results are also uploaded to a password protected website where they can be retrieved by the client.
We will discuss any validated sanctions directly with the client and will provide guidance on managing the sanctions internally. As part of our initial assessment, we ensure that clients have internal documentation and reporting procedures in place to manage this situation when it occurs. Our team has extensive experience in human resources management and can guide your HR team appropriately.
Reporting to OIG/Other Agencies
In addition to assisting with internal reporting procedures, we will also provide guidance on reporting validated sanction results to external federal and state agencies, as necessary. Under new Affordable Care Act (PPACA) regulations, reporting and restitution of payments made to excluded parties must occur within 60 days. Our reports include all the documentation necessary for the client to submit to these agencies.
Quarterly Review & Updates
Since regulations and best practices change so frequently, we provide our clients with quarterly regulatory updates and review of their OIG screening programs, to ensure a high standard of performance and effectiveness in the long-term.