Knowledge Library Sanction Checking and Resolving Potential Matches
Thursday, March 21, 2019

Sanction Checking and Resolving Potential Matches

Sanction checking is mandatory and requires considerable time, staff commitment, and cost as result of the number of databases to be searched, and frequency. The OIG calls for screening employees, physicians, vendors, and contractors against their List of Excluded Individuals and Entities (LEIE). CMS calls for screening against both the LEIE and GSA’s debarment listing, as well as calling on State Medicaid agencies to develop their own sanction databases and require monthly screening against it, along with LEIE and GSA. Other federal and state sanction databases impact on the health care provider sector, including those of DEA and FDA. The result has been significant increased burden greatly, not only for the compliance office but also human resources and procurement. Many healthcare providers now rely on vendor search engine tools to assist in sanction checking, however these tools address only a small part of the process. The bulk of the effort is investigating and resolving potential “hits,” and preparing a signed report to evidence it was all done appropriately. Failure to meet these standards may result in enforcement actions and impact on conditions of Medicare/Medicaid participation Hear from the experts who will address this subject and provide useful tips in meeting the challenge of effective sanction checking.

Learning Objectives include explaining:

  • Increases in screening burdens
  • Different sanction databases 
  • Exclusions vs. Debarments
  • OIG position on enforcement
  • CMS enforcement role
  • Strategies to reduce burden
  • Best practices/checking tools
  • Methods to resolve potential “hits”

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