Why Screen Vendors?
While many organizations are aware that they have to screen their employees and providers, many are not aware that they also need to be screening their vendors and contactors. Just like with excluded providers and individuals, excluded entities may not bill Federal or State Health Care Programs for services ordered or furnished, directly or indirectly, if it is payable in whole or in part, by a Federal Health Care Program.
The Office of Inspector General interprets § 1001.1901(b) from the Code of Federal Regulations as a requirement for providers to screen vendors/contactors and authorizes the imposition of civil money penalties and overpayment exposure “if an excluded person [or entity] participates in any way in the furnishing of items or services payable by a Federal health care program.”
The civil monetary penalties that the OIG has the authority to impose can be up to $21,562.80 for each item or service furnished by the excluded person or entity, as well as assessments of up to three times the amount claimed.
Just like with individuals, screening entities for exclusions is not only clearing yourself from civil monetary penalties from the Office of Inspector General, but is also mitigating your organizations overall risk. If a company has been either excluded or sanctioned by GSA SAM, OFAC, or any other regulating organization, then you are most likely working with an organization that has taken part in fraudulent business activities. The last thing you would want for you organization is to wind up working with a vendor or contractor that could rope you into their fraud.
Which Vendors Should You Screen?
A constant question we get here at Exclusion Screening is “Which vendors should I screen? Do I need to screen the janitor that cleans up every night? Do I need to screen the laundry service that washes our sheets?” Well we have some guidance below that the OIG has provided and that we recommend people follow.
Many organizations, especially those in health-care deal with almost a hundred if not more vendors and contractors. But the OIG states that its emphasis on screening vendors and contractors for exclusions regards “items or services integral to the provision of patient care.” So what does that mean? We believe that this means that you need to screen any vendor or contractor has access to any of the following four categories below:
- Patients. If they have access to your patients then they 100% need to be screened.
- Financials. This means almost any billing company that you work with NEEDS to be screened.
- Patient Facilities. If they are in your facilities at all they need to be screened. The last thing you want is for HIPAA information to be left out in front of someone that has been conducted any sort of fraud. You want to fully know exactly who is in your building and office!
- Patient Records. When dealing with patient records, you want to make sure that their information is secure and confidential. That means screening your I.T. services, billing company, and collections company.
We offer various different forms of screening to ensure that you can thoroughly trust the vendor or contractor you are working with. We can screen vendors and contractors by the following ways:
- Provider Name. If you want to screen by the name of the owner or owners.
- Company Name. You can screen by just the name of the company or with the names that the company is doing business as.
- NPI Number. If you have the provider number then you can just provide us with that and we can provide you with your search results immediately.
- Web Services. Automate your vendors screen by integrating into our Safer web services.
To see a full list of every database we can screen, please click here.