Whose Job is Exclusion Screening?

Posted by Frank Strafford on June 5, 2015 in Exclusion Screening,

Whose Job is Exclusion Screening?

Is it the Compliance Department’s or HR? Many healthcare companies find this particular issue a source of confusion, which often results in astronomical penalties. Exclusion screening requires a specific policy and procedure that must be strictly implemented at all times. Both HR and the Compliance Department play important parts in achieving precisely this.

 

The role of Human Resources begins right at the recruitment stage, and in the case of exclusion, culminates in the termination phase. During the initial interview, the HR head must ask proper questions in order to determine if the potential employee fills the job requirements. Individualized Assessment should be used in case of a past criminal misconduct showing up in the screening process, as a best practice endorsed by the Equal Employment Opportunity Commission. HR must also do thorough background checks for all employees, as well as monthly monitoring post-hire.

 

The Compliance Department in turn must make sure that the company’s compliance program is strong, effective, and strictly implemented. In developing their compliance policies, the department should ensure there are both general standards and case-by-case procedures for their employees. Compliance Department is also responsible for the training/education, monitoring and auditing, enforcement, investigation, and reporting of any compliance issues.

 

It is also the job of the people making up the company’s Human Resources and Compliance Departments to be familiar with OIG protocol and any guidance involving exclusion screening. Being updated on these guidelines will ensure a thorough investigation in the case of exclusion.

 

Both HR and the Compliance Department play proactive roles in exclusion screening and policy implementation. Along with an effective compliance program, these departments must work together to ensure that mandatory exclusions are enforced, and penalties avoided altogether.

 

 

About Frank Strafford

About Frank Strafford

Related Articles

Understanding Which Excluded Employees & Entities Are ...

September 19, 2017

When is an Excluded Individual or Entity Problematic? According to federal law, the OIG is legally permitted to enforce CMP (Civil Monetary Penalties) upon any individual or entity which breaches the...

What Are the Effects of OIG ...

December 22, 2014

A person can end up on the OIG List of Excluded Individuals for a range of reasons and the main effect of being excluded is that individuals cannot receive payment through Medicare, Medicaid or any ot...

Streamline Verify Certified with SOC 2 Type ...

April 12, 2021

Like you, Streamline Verify puts security first! In healthcare, data is sensitive and handling it properly is a pressing concern. That’s why we’re careful to implement cutting-edge systems and pro...