Bringing new employees into an organization brings plenty of excitement and opportunity for any type of organization but especially one associated with health care. As an organization expands its workforce, you will have the opportunity to serve many more patients or customers than before! However, finding the right employee for your organization is also a big responsibility. Finding the right person isn’t only about verifying educational qualifications and work experience; it’s also about verifying that the person you are considering can legally work in your field.

Exclusion screening are one of the ways in which organizations like yours conduct thorough due diligence regarding potential hires; however, they do not require a great deal of technical knowledge to implement and maintain! Exclusion screening are simply a precautionary measure taken by your organization to protect itself, its resources, and its reputation.

An exclusion screening is done by going through the list of prohibited employees in healthcare. This list, which can be thought of as a "Not Allowed" list for the healthcare industry, consists of all individuals (e.g., doctors, nurses, and administrators) who have acted inappropriately in some way—e.g., committing fraud, abusing patients, or not paying back their student loans. If a member of the healthcare workforce appears on this exclusion list, the federal government may prevent that person from working for any federal program, including Medicare and Medicaid.

Conducting an exclusion screening is when you verify (in addition to conducting a background check) that your candidate does not appear on any of the federal government's exclusion lists. If you employ a person who is on an exclusion list, your company is subject to fines, which can reach thousands of dollars per each service provided by that individual. The federal government expects that you will screen potential employees to ensure compliance with their regulatory requirements.

Comprehending Sanction Checks

Sanction Checks are a more in-depth screening process than simply depending on exclusion lists, which come mostly from federal authorities (such as the OIG or SAM.gov). A Sanction is an action taken to discipline a professional’s Credential.

For instance, if a nurse has been sanctioned by the state nursing board for stealing medications, although the nurse is not excluded from Medicare federally, they still could potentially put patients’ lives at risk. If all you do is check an exclusion list to determine whether a nurse is prohibited from working in Medicare, you miss this critical indicator (red flag). Sanction Checks provide information on state boards as well as any other regulatory agencies that may have jurisdiction over licensure, such as whether a license is inactive, suspended, or revoked.

In summary, a combination of both types of checks provides a more complete view of who you are hiring. Not only do you want to know if the professional is prohibited from working on a federal level; you must also want to know whether they are permitted to practice in good standing within the state or territory where they are employed.

Why can't you skip this step?

Financial Protection: The penalties for hiring an excluded person are severe. Many small medical offices and practices have gone under because they failed to carry out Exclusions checks on their employees. This is considered fraud in the eyes of the government, as you are billing for services rendered by someone who shouldn't even be there.

Safety of Patients: Many of the people on these lists are there for a good reason, whether it be for committing financial crimes, neglecting caring for patients, or having issues with substance abuse. Exclusion checks will ensure that your patients are not exposed to potentially harmful individuals.

Confidence: The reputation of your practice takes years to develop and minutes to ruin. Once it becomes common knowledge that you employ people with a history of fraud or abuse, you will lose the confidence of your patients.

A common misconception among businesses is thinking that Exclusion Screening only applies to new employees. Businesses only check the Exclusion Screening Lists at the initial stages of employment or when new employees have started working, and then do not conduct anymore checks.

However, an employee can get into trouble after they begin employment with that business — for instance, the employee may lose their professional license, be convicted of a crime, etc. The best practice for conducting Exclusion Screening is to screen every employee at least once a month.

To sum this all up: while it may appear to be boring to comply with State and Federal regulations, compliance is actually another way to demonstrate that your business is committed to creating a safe workplace and also the importance of conducting Exclusions Screening and Sanction Checks to maintain a quality work environment and provide the highest level of care to your patients.

To correctly conduct screening you do not need to consult an attorney. Many automated services exist today that will help automate this monthly process for you. By using these automated systems, you can concentrate on providing care for your patients and grow your business without having to worry about whether someone has an issue on the Exclusion Screening List.