If your organization provides healthcare services, you already know that the nature of your business makes it inherently risky.  Whether we’re talking about a delicate medical procedure or billing for services rendered, danger exists. If you employ or contract with the wrong people the consequences could be costly.  A comprehensive healthcare-enhanced background screening program will help mitigate your risk, keep your patients safe, and protect your organization’s image by making it much more likely you will exclude those candidates with an unsavory past.

Because you’re providing services to vulnerable populations and billing governmental agencies that require a deeper investigation into the professional conduct of the providers and organizations that receive their funds, it’s required that your background screening process cast a wide net. In order to be in compliance under the Affordable Care Act (ACA) and to avoid civil monetary penalties (CMPs) for employing or contracting with excluded providers, that broad spectrum investigation must, at a minimum, determine if a provider appears on the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities (LEIE). Seems easy enough right?  Unfortunately, OIG recently released a report showing that 12% of providers who were terminated for cause in one state continued to participate in other States’ Medicaid programs nearly 2 years later.  The issue at hand is that there is no single reliable source today for identifying providers who have been terminated from a state program and must be excluded from participation in any other state. This makes it mandatory to check all available state specific exclusion lists in addition to the LEIE.

To address this daunting task, Hire Image offers a comprehensive healthcare specific search called MedScan USA (available for both individual providers and entities). MedScan USA provides sanction information about medical providers, contractors, non-medical providers and organizations.  It also provides disciplinary action taken by state agencies, licensing and certification agencies for all 50 states and the District of Columbia and much more.  The data sources are from more than 1200 direct primary sources. Some of these sources include:

• Patriot Act (OFAC, FBI, FinCen, etc.)
• Office of Inspector General (OIG)
• General Services Administration (GSA)
  • System for Award Management (SAM)
• Federal Drug Administration(FDA)
• Drug Enforcement Administration(DEA)
• Health and Human Services(HHS)
  • Office of Research Integrity (ORI)
  • Public Health Service (PHS)
• Tri Care Sanctions List
• State specific exclusion lists

Some of the most common questions or concerns that arise with healthcare screening have to do with determining which persons or entities to screen and how often.  In the OIG’s updated Special Advisory Bulletin they provided guidance on these questions:

“…..review each job category or contractual relationship to determine whether the item or service being provided is directly or indirectly, in whole or in part, payable by a Federal health care program.  If the answer is yes, then the best mechanism for limiting CMP liability is to screen all persons that perform under that contract or that are in that job category”

“….screening employees and contractors each month best minimizes potential overpayment and CMP liability”

Even with the MedScan USA product addressing the compliancy needs of a healthcare organization both for initial and monthly screenings, there are other components of screening that are needed to safeguard the workplace and ensure the best possible hiring decisions. Adding the following components will provide the additional information needed to build the most comprehensive screening program.

• Address and Social Security Number Trace –verifies the applicant’s social security number matches the applicant, and reveals alias names and previous addresses.
• County and/or Statewide Criminal Records – Court records are searched for felony and/or misdemeanor records at the primary source of the record.
• Nationwide Criminal Database –With over 500 million records from over 1,600 sources, this supplement to the local searches may uncover criminal activity that occurred outside of where the applicant lived or worked.
• Sex Offender Registry Search –identifies individuals convicted of sex crimes by utilizing sex offender registries in all 50 states, the District of Columbia, the five principal US territories and federally recognized and registered Indian tribes.
• Federal Criminal Search –includes violations of Federal law that are recorded in US District Courts. Federal crimes involve serious offenses such as embezzlement, robbery, drug trafficking, kidnapping, and internet crimes like child pornography.
• Drug Testing w/ Expanded opiates and healthcare specific panels –Traditional 5 or 10 panel tests have been used for years across all industries, but they may not hit all the right targets for a healthcare organization. While it’s true that marijuana and cocaine still have the highest positivity rates, opiates like Oxycodone are on the rise. Adding expanded opiates to a drug panel will help uncover this. Healthcare specific panels can be tailored to add specific drugs of concern to the panel based on your organization’s needs.
• Professional License Verification –verifies the credentials of medical professionals as well any other licensed individuals.
• Education Verification –verifies graduation date and degree earned, but equally as important verifies the accreditation status of the institution (not a diploma mill).
• Employment Verification -verifies the past employment of the applicant including, start date, end date and position. Other information obtained may include ending salary, reason for leaving, and eligibility for rehire.

 With the constantly changing rules and regulations in the healthcare industry, a comprehensive background screening program that both keeps you in compliance and your patients and employees safe requires frequent review. When was the last time you reviewed your organization’s screening program?  Contact us to learn how Hire Image can help streamline your processes and create the right screening program for your business.