OIG Compliance NOW provides comprehensive screening service for all types of individuals and entities, including employees, physicians, referring physicians, volunteers, and vendors/contractors (entity names as well as employees). We would support health care institutions in providing all individuals and entities with a clear and conspicuous disclosure, in writing, that the OIG Sanction Report will be obtained for monthly sanction screening purposes, and such disclosure would be contained in a document containing only this disclosure. We would also advise health care institutions with regard to other disclosures and other applicable state and local laws for the type of report requested, including all disclosures which are required before requesting that OIG Compliance NOW prepares the Sanction Report and before taking any adverse action based in whole or in part upon any information contained in the Report.

Turnaround time for list screening is 48 hours; validation activities will require more time and will depend on resource availability at federal and state program integrity unit offices.

Any client with validated exclusions will first be contacted by telephone prior to the generation of the monthly report. When an association match is found, an OIG Compliance NOW investigator takes that record and verifies that the employee or vendor is sanctioned and/or excluded. After all of the association matches have been investigated and verified, a final report is generated. The final report includes a positive match report including a “snapshot” report from the individual (state) OIG/GSA/State database. All verified data includes, name of sanctioned person or entity, owner of entity, reason for sanction, verification of name(s) or entity name, date of birth, social security number, EIN or TIN, dates of sanction and state of sanction. Positive matches will be listed in detail for follow up and reference. The state level name association matches are verified through verbal conversation with a contact at the state(s) Medicaid/Medicare Program Integrity Unit. OIG Compliance NOW captures these results to their database and includes this in the deliverable report.

We are prepared to offer clients a comprehensive compliance solution for sanction screening which includes a sanction screening checklist, quarterly updates of new requirements/regulations, and an annual review of the program to encourage the development of a long-term, “best practice” compliance program. We stay connected to various federal, state and professional organizations to stay alerted of changing regulations and practices.

Our comprehensive screening process effectively checks for sanctions of entities including all offices and branches in any part of the United States.

Our standard procedure is to report all active exclusions that appear in our monthly search results. However, using our unique and proprietary OIG Investigations tracking system, we are able to automatically identify individuals that were investigated in previous months and list those individuals as “previously identified and reported to client”. In terms of “clearing” excluded individuals and allowing them to work within the Medicaid system, regulations do state that an exclusion can be overcome when OIG finds that significant factors weigh against exclusion. In the case where a health care institution client feels that a sanctioned individual or entity can be “cleared” to work, OIG Compliance NOW will contact OIG to discuss the factors in greater detail, which will involve: circumstances of the misconduct and seriousness of the offense; the individual’s role in the case of a sanctioned entity; the individual’s actions in response to the misconduct; and other information about the entity. It may be permissible for the health care institution to apply for a waiver for the excluded individual.

Part of our validation process includes obtaining documentation from local, state and federal agencies regarding the nature of the exclusion. We then share this documentation with the health care institution as part of our master validation report.

Results are ALWAYS VALIDATED before any communication back to the health care institution. Names of excluded individuals and entities are confirmed to be accurate through a manual investigative process that involves verbal communication with local, state and federal agencies, as required.

Results are ALWAYS VALIDATED before any communication back to the health care institution. Names of excluded individuals and entities are confirmed to be accurate through a manual investigative process that involves verbal communication with local, state and federal agencies, as required.

• The organization exercises due diligence to prevent and detect inappropriate conduct by the Medicaid provider

• The organization promotes an organizational culture that encourages ethical conduct and is committed to compliance with the law.

• The compliance program is reasonably designed, implemented, and enforced so that the program is generally effective in preventing  and detecting improper conduct.

Failure to prevent or detect specific offenses does not necessarily mean that the program is not generally effective in preventing and detecting such conduct.