OIG Compliance requires a lot of things to remember. However, since many people respond more pro-actively when they learn of the possible consequences, here is a short “to-don’t” compliance list instead of the usual “to-do”.
- Don’t be complacent about your employees’ status.
Your employees may have initially been cleared from exclusion screening upon being hired. Being complacent about their status, however, is not acceptable. Many employers make the mistake of not screening against every Federal and State databases on a monthly basis. Your employees’ names should also be screened for all possible variations, including diminutives and maiden names.
- Don’t burden yourself with DIY exclusion screening.
Verifying whether an individual is on the excluded list or not is a big responsibility. Doing it yourself can be time consuming and tedious.
The key is to get a reliable automated exclusion screening software to lighten the load of OIG compliance and to make sure the screening is thorough. You don’t have to do it on your own, which can save you some expensive and embarrassing mistakes.
- Don’t rely on the OIG for notifications on excluded individuals.
Expect no warnings or notifications from the OIG about excluded individuals – this is simply not a service they provide. Your task as an employer is to search your state’s required databases, aside from SAM.gov, Federal exclusions, and Medicaid exclusion databases monthly.
- Don’t think little “mistakes” won’t cost you.
Always remember that ignorance of an employee’s status is never an acceptable excuse to the OIG. A misspelled name here, an ignored nickname there, or failure to check against important databases can cost you plenty in penalties or lawsuits. Keeping an excluded individual on your staff (whether it’s intentional or not) could result in fines between $30,000 and $300,000.