The screening of contractors, vendors and agents is one of the most confusing tasks faced by health care providers and suppliers when conducting exclusion and sanction screening activities. A wide number of questions may arise when attempting to meet their screening obligations.
In May 2013,[i] the Department of Health and Human Services, Office of Inspector General (OIG) issued guidance discussing the screening obligations of participating providers and suppliers. The OIG interprets §1001.1901(b) to requires providers to screen vendors/contactors and authorizes the imposition of civil money penalties and overpayment exposure “if an excluded person participates in any way in the furnishing of items or services payable by a Federal health care program.”
[i] “UPDATED – Special Advisory Bulleting on the Effect of Exclusion from Participation in Federal Health Care Programs.” Department of Health and Human Services, Office of Inspector General (May 8, 2013).
As a rule, health care providers and employers 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. For example:
Many health care providers and suppliers have a large pool of contractors, vendors and agents that they work with from time to time. One issue that arises is whether a particular contractor or vendor performs services or provides supplies that are paid “in whole or in part” with funds that are derived from Federal health care benefit program revenues. A second issue to be considered is whether the services or supplies are integral to the overall basket of services provided to Federal health care program beneficiaries. For example:
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Are you unsure your screening requirements depending on your business and location? Our FREE Consultation has you covered. It includes: An overview of exclusions in addition to an overview of your exclusion requirements, and a demonstration of our product and service (SAFER) will be performed prior to a presentation of your personalized solutions. This consultation for your benefit only!