Vendor – Frequently Asked Questions
We cannot give you legal advice, but we can assist you with the process by providing supporting documentation. You should speak to your legal counsel and human resources departments before taking any action with the excluded employees
The report will either show that no employees are excluded, or it will show a list of the employees that we have confirmed as having excluded status. In the case of excluded employees, you will first receive a phone call from one of our investigators to discuss the situation with you, before we publish the report. The report will also show if we are unable to validate any name association “hits” due to the lack of identifying information, such as Social Security Number.
A report will be generated each month and uploaded to your account. You will be able to access your reports, including past months’ screenings for 18 months, by logging in on the www.sanctionscreeningnow.com website. We maintain all screening results and reports for 5 years.
The screening process takes 48 hours, not including validation. You will be able to login to your account and review the screening results.
OIGCN requires a social security number to validate any name associations that are discovered during the screening process. Even having the last 4 digits of the SSN is not adequate to confirm or disprove excluded status. Name associations that are missing SSN information and cannot be verified will be listed on the screening report as “unverified”.
You will receive an online confirmation indicating that the names/file has been successfully received. If there are any errors with your file’s formatting, we will notify you and work with you to make the corrections.
In this case, we suggest that you contact your payroll company. They will be able to assemble a list of your employee names, and submit the file for you.
What if there are several users in our organization who need to login to the system? Can we have multiple users and different access levels?
Yes. The OIGCN system can accommodate multiple users from each vendor organization, and we can provide different access levels depending on the user’s need to upload and/or retrieve reports. However, each vendor should register only ONCE with OIGCN, and there should be only ONE upload of the data file per month.
There are two ways to submit names for screening. You may either enter the names of employees into the online data grid sheet, or you may upload a CSV data file that contains all the names. Once you register with OIGCN, you will receive an email that outlines data file and formatting requirements for your upload list.
Each month, you will need to submit a complete list of names that has been updated for any changes that have occurred since your last submission (new hires, terminations). We are sorry, but we cannot receive only added names or notes about who has been terminated; we MUST receive a complete and new list each month. The OIGCN internal system updates our database lists for screening at minimum every ten days, and maximally every thirty days.
Employees to be screened fall into two categories: 1. those that are directly involved in the claim/order process, that are using/receiving medical assistance money, and 2. those that “causing medical assistance money to flow” to the healthcare facilities that you service. Once you register with OIGCN, you will receive an email that outlines data file and formatting requirements for your list.
If you need assistance, please contact our call center customer service team at 607-240-2400.
On the Login page, you will see a button for “Forgot Password”. Please click here and follow the instructions.
For your Business Name, we need the EXACT name of your business, as shown on the State Registration form received from the State in which you are registered to do business. Please enter correct spelling, punctuation, capitalization, and spacing of your company name. For TIN/EIN, we need the taxpayer identification number that you use when filing your tax returns. If you are an independent contractor, you will need to enter you Social Security Number (SSN). All information that you share with us will be kept securely and confidentially, and will not be shared with other individuals or organizations.
Payment options are listed on the website. If you need assistance, please contact our call center customer service team at 607-240-2400.
Please go to www.sanctionscreeningnow.com and click on the orange Register button in the upper right corner. On the first screen, as the Type of Business, you should select “Vendor/Business” if you are a company, or “Vendor/Individual” if you an independent contractor working without a defined company name. Upon successful registration, you will receive an email containing your username and password, as well as instructions for uploading your data file. After you have registered, you will use the orange Login button to login to the website.
What is the cost of using OIG Consulting NOW as our third party administrator for sanction screening?
There is a small, fixed annual cost for vendors that covers registration of your company, monthly sanction screening and validation for your employees, and notification to the healthcare institution(s) that you service that you are in compliance with the program. You are only required to pay this fee once per year, regardless of how many healthcare institutions you serve.
You have multiple options, including conducting the sanction screening yourself, using OIGCN, or using another third party administrator. Regardless of the option that you select, you will be required to notify each of your healthcare providers on a monthly basis that you are conducting sanction screening. The advantage of using OIGCN is that we will screen your data files and notify each of your healthcare providers on a monthly basis that you are in compliance.
Excluded individuals are not allowed to receive federal money, unless a waiver is granted by the Office of Inspector General. Without a waiver, you will need to ensure that any excluded individuals do not receive federal funds. Our company can assist you with the management of any exclusions. You will need to involve your HR and Legal teams prior to taking any employment actions.
It is up to the hospital to determine what it will accept as “proof” of monthly screening for vendors who conduct screening themselves. If you work with OIGCN, we will submit proof to the hospital that you are conducting monthly screening.
Employees to be screened fall into two categories: 1. those that are directly involved in the claim/order process, that are using/receiving medical assistance money, and 2. those that “causing medical assistance money to flow” to the healthcare facilities that you service. This applies to employees at any of your locations. Again, if you need further clarification from the healthcare or education facility, please reach out to them.
The screening requirement is based on how your vendor organization “causes Medicaid money to flow” to the healthcare facility. Some vendors are providing products, like assistive devices for IEP students, and these vendors need to screen their entity names. Others are providing specialists (individuals) to the healthcare facility that provide services. In this case, both the vendor entity name and the names of the individual specialists need to be screened.
Vendors do not need to be submitting claims to be required to screen. As a contractor to a school or hospital, your vendor organization could be “causing the Medicaid money to flow” from the federal system to the school or hospital that has notified you. This means that your organization “adds value to a claim” or is “used to make a claim” or “provides products or services that show up on a rate-based report”. It is up to the individual healthcare facility to determine how to calculate its rates for reimbursement and to create cost reports, and to include vendor products/services in this process. If you have questions about why you have been asked to conduct sanction screening, please reach out to the organization that has sent the letter to you.
Exclusion can be caused by convictions for healthcare program-related fraud and abuse, including patient abuse, as well as felony convictions for controlled substances. The Office of Inspector General (OIG) of the Department of Health & Human Services has the authority to exclude individuals and entities. For a list of mandatory and permissive exclusions, please see here: http://www.oig.hhs.gov/exclusions/authorities.asp
The letter means that you are a Vendor organization that provides services to health care providers or other organizations that receive federal/state medical assistance funding (e.g., Medicaid). Federal and state regulations require healthcare providers to notify you of your requirement to conduct sanction screening to determine if your entity and any of your employees are excluded from receiving medical assistance funding.