5 New Year’s Resolutions for the Compliance Officer

Posted by Frank Strafford on December 31, 2014 in Exclusion Screening,

As 2015 begins, here are five things that you can do to tighten up compliance at your facility.

1) Check OIG exclusions monthly.

Every month.  Religiously.  Because the LEIE is updated monthly…and because your facility can be held liable for employing excluded individuals beginning from the time that the exclusion is posted on the OIG site.

2) Screen EVERYONE — not just medical staff.

That includes administrators; medical billing agents; accountants; claims processors; ambulance drivers and dispatchers; CEOs; office managers; and any other sort of staff members or vendors that are in any way involved in the Medicaid process.  Because although they may not be dispensing medical services, excluded individuals are barred from involvement in any aspect of Federal health care claims, as per the OIG’s Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs.

3) Screen against ALL states — even if you think you don’t have to.

Because you just might have to.  Different states vary in their protocols (actually, some of the state officials that we contacted seemed confused themselves regarding whether or not exclusion in a different state would automatically exclude a medical provider from participation in their own state’s health care programs); but whether or not your state requires it, comprehensive exclusion screening is just good practice.  You never know when an exclusion in one state will ‘spread’ to another – and you want to be safe before that happens.

4) Consider adding OFAC to your screening protocols.

It’s optional, but it’s a good idea anyway.  Particularly since with the right software, you can add the extra search without a drop of extra effort — and it’s one more layer in compliance protection.

5) Consider adding the Death Master File to your screening protocols.

Ditto above.  It’s simple as anything; it ensures that you don’t have to hassle with fraudulent employees; and it’s a clear demonstration of compliance responsibility, should you ever have to face an audit.

About Frank Strafford

About Frank Strafford

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