Healthcare Sanctions Background Checks: Why They Matter

Hiring qualified healthcare professionals is essential for organizations to provide high-quality patient care and avoid costly compliance violations. 

Background checks are a critical part of the hiring process, particularly healthcare sanctions checks that screen for disciplinary actions and exclusions.

Healthcare providers and organizations that employ clinicians, technicians, administrators, and other staff involved in patient care must be diligent about conducting thorough sanctions screenings. 

Failing to identify individuals or entities excluded from programs like Medicare and Medicaid can expose organizations to severe financial penalties, reputational damage, and jeopardize their eligibility for federal funding.

Why Healthcare Sanctions Background Checks Matter

Healthcare organizations have an ethical and legal obligation to ensure they employ qualified, trustworthy professionals to provide patient care. 

Conducting thorough sanctions background checks is a critical part of meeting this obligation. 

The consequences of hiring an individual or entity excluded from federal healthcare programs can be devastating for the following reasons:

Massive Financial Penalties: Employers can face civil monetary penalties up to $10,000 per day per violation for employing an excluded individual or entity. There may also be additional penalties of $10,000 or more for each related claims submission.

Loss of Federal Funding Eligibility: Organizations that hire excluded parties risk losing their eligibility to receive reimbursements from federal healthcare programs like Medicare and Medicaid. This can be catastrophic for a healthcare provider's finances.

Reputational Damage: News of employing a sanctioned individual, especially for offenses like patient abuse or fraud, can severely tarnish an organization's reputation and public trust.  

Beyond the OIG exclusion list for federal programs, healthcare employers must also be mindful of sanctions and disciplinary actions from other sources. 

This includes monitoring exclusions and disciplinary records from state licensing boards, prescription drug monitoring programs, terrorist watch lists, and more. 

Compliance with regulations like the Affordable Care Act (ACA) and HIPAA also necessitates robust employee background check protocols. The ACA has specific requirements for screening all employees with access to patient records.

Failing to implement comprehensive healthcare sanctions screenings exposes organizations to substantial legal, financial, and reputational risks. 

Investing in proper background checks can ultimately save millions by avoiding costly penalties and eligibility issues.

What is an OIG Exclusion Check?

An OIG exclusion check refers to screening an individual or entity against the List of Excluded Individuals/Entities (LEIE) maintained by the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services.

The OIG has the authority to exclude individuals and companies from participating in federally-funded healthcare programs like Medicare, Medicaid, and others for certain violations. Reasons for exclusion include:

• Convictions related to patient abuse or neglect.

• Healthcare fraud convictions. 

• Felony convictions for financial crimes like theft or misappropriation of funds.

• Felony convictions involving illegal manufacture, distribution, or dispensing of controlled substances.

• License revocation or suspension by state licensing authorities. 

Once excluded by the OIG, individuals and entities are prohibited from working for or contracting with any organization that receives reimbursements from federal healthcare programs.

Healthcare providers, practices, hospitals, nursing homes, clinics, and other employers are required to check the LEIE database before hiring new employees or engaging contractors to avoid violations. The OIG can levy substantial civil monetary penalties against organizations that employ or enter into contracts with excluded parties.

While checking the OIG's exclusion list is mandatory, conducting this check alone is often insufficient. 

The LEIE has limitations and may miss disciplinary actions or sanctions from other critical data sources. Healthcare employers need to make sure they are comprehensively screening their workforce.

Going Beyond the OIG Exclusion Check

While checking the OIG's List of Excluded Individuals/Entities (LEIE) is a crucial step, healthcare employers need to go beyond just this single database for comprehensive sanctions screening.

The LEIE has several key limitations:

• It includes exclusions from federal healthcare programs, but misses disciplinary actions from drug enforcement agencies, and other sources.

• There can be delays before newly excluded individuals/entities appear on the LEIE after being sanctioned by states or other federal agencies.

• It requires periodic manual checking or cumbersome database downloads to stay up-to-date.

To fully assess risk and ensure workforce compliance, healthcare organizations should implement background checks that search across a comprehensive array of sanctions data sources beyond just the OIG.

These data sources include:

• State licensing board disciplinary action databases.

• State Medicaid/Medicare exclusion lists. 

• DEA/Controlled Substance Act violation records. 

• Federal debarment sources like the GSA EPLS.

• National Sex Offender Public Registries.

A multi-faceted screening approach provides much deeper visibility into violation histories, confirmed disciplinary actions, license sanctions, and other critical details about potential employees, vendors, and contractors.

This broader screening coverage, combined with automated monitoring and detailed reporting, allows healthcare employers to make fully informed decisions that adequately assess risk during the hiring process.

Streamlined Sanction Screening

Our Health Care Comply Plus™ (HCC+) solution provides healthcare organizations with the most comprehensive sanctions screening available. 

Going far beyond just checking the OIG's exclusion list, HCC+ searches across an unrivaled array of data sources to deliver in-depth violation histories on individuals and entities. 

HCC+ offers unmatched coverage spanning OIG exclusion lists, GSA/EPLS debarment lists, disciplinary actions from all 50 state licensing boards, DEA and controlled substance violations, Medicare/Medicaid fraud and sanctions data, and over 15 years of historical sanctions information. 

HCC+ meets all healthcare regulatory requirements, including the ACA, OIG guidelines, and includes global anti-terrorism and Patriot Act screening capabilities. 

With auditable documentation on all screening decisions and dedicated compliance analysts available, you can trust HCC+'s compliance. 

The solution takes the guesswork out of healthcare sanctions screening, allowing you to confidently assess risk and make fully informed hiring decisions that safeguard your organization and uphold the highest standards for patient safety.

Don't rely on limited OIG checks that miss critical sanctions information. Insist on the comprehensive screening power of HCC+ to elevate workforce compliance.

Prioritize the industry's most rigorous background screening protocols with HCC+. Contact us today to learn more about how Health Care Comply Plus™ can streamline and strengthen your hiring processes while safeguarding your healthcare organization.