What is a healthcare sanctions check?
A healthcare sanctions background check is used by employers in the healthcare industry to confirm their candidates are in good standing. This check may search:
FACIS and 1,000s of government sources
To report exclusions and any penalties, suspensions, or disciplinary action taken against a healthcare professional.
The federal OIG exclusion list
To reveal healthcare providers who are sanctioned and excluded from participating in federally funded programs.
The federal SAM database
To determine whether contractors or entities are excluded from working with the government.
Why sanction checks are important
Healthcare organizations use a sanction check OIG to help protect patients, minimize risk, and maintain their federal funding. These checks help you:
Prioritize patient safety
A candidate may be on the OIG exclusion list for reasons including patient neglect and abuse.
Avoid OIG sanction check penalties
Hiring sanctioned contractors or entities puts your organization at risk for penalties or losing federal funding.
Meet state and federal requirements
Healthcare sanction checks help you maintain eligibility for Medicare, Medicaid and other state and federal programs.
What you’ll learn from a healthcare sanctions check
An OIG/SAM background check lets you know if your candidate or employee is sanctioned. Depending on the search level, report results may include:
Agency or authority name
The name of the source or board that took the disciplinary action, such as a state Department of Medicaid.
Registry database
The name of the database the individual’s name appears, such as the Medicaid Provider Exclusion and Suspension List.
Sanction details and dates
A healthcare sanctions level 3 may report the reason for the sanction, whether the sanction is currently active, or the end date.
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Checkr’s healthcare sanction check options
If you’re hiring in the healthcare industry, Checkr’s FACIS check (Fraud and Abuse Control Information Systems) and Global watchlist search is recommended to manage risk and compliance. Checkr offers the recommended levels of screening to help your organization meet state and federal requirements for healthcare-related screening. The following checks may be run as a standalone:
FACIS Level 1 / 1M
Meets requirements of the Office of Inspector General (OIG) Compliance Program Guidance. Includes a search of the federal Excluded Parties List System (EPLS) maintained by the General Service Administration, and the List of Excluded Individuals and Entities (LEIE). It also searches state-specific Medicare and Medicaid data where available. This search corresponds to the industry-wide FACIS Level 1M, which includes a state-level Medicaid search.
FACIS Level 3
This is the gold standard of healthcare exclusion and debarment screening. This check includes all of the items contained in FACIS Level 1/1M (OIG sanction check) and the sanctioning boards from all 56 US jurisdictions across all provider types. This check accesses more than 3,000 sources. While this search exceeds minimum federal requirements, it offers full coverage for a high-level risk management policy.
Global watchlist search
Identifies whether a candidate’s name appears on domestic or international watchlists and includes government and regulatory databases that list individuals who are prohibited from working in the healthcare industry. Sources searched include: The Office of Inspector General for the U.S. Department of Health and Human Services (OIG-HHS), System for Award Management (SAM), FBI Most Wanted Lists, Interpol’s Most Wanted Lists, and Office of Foreign Asset Control Sanction Lists (OFAC).
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Frequently asked questions
Learn more about healthcare sanction checks
Healthcare sanctions checks are conducted by organizations hiring medical professionals to protect patients and employees, minimize risk, and maintain their federal funding. A healthcare sanctions background check reviews multiple government lists for healthcare sanctions against an individual or entity, such as a contractor or provider, who may be excluded from participating in federal healthcare programs.
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What is a sanctions check?
A healthcare sanction check searches more than 1,000 United States government sources for any penalties, suspensions, or disciplinary action taken against a healthcare professional. The US Department of Health & Human Services Office of Inspector General (OIG) prohibits healthcare organizations from hiring any person or entity that has been sanctioned or appears on federal exclusion lists if they wish to participate in federally funded healthcare programs like Medicare and Medicaid.
What is included in a healthcare sanction screening?
Typically, a healthcare sanction screening searches the following lists:
- The OIG Exclusion List of sanctioned individuals and organizations excluded from participating in Medicare, Medicaid, and other federal health programs
- The System for Award Management (SAM) database of contractors that are approved for, and excluded from, federal contracting opportunities
Depending on the position, employer needs, and applicable laws, a healthcare sanction check may also search state-level Medicare and Medicaid exclusion lists and state medical boards sanctions.
What is an OIG sanction check?
An OIG sanction check is a type of healthcare sanctions background check used to search the OIG exclusion list, formally known as the List of Excluded Individuals/Entities (LEIE). The OIG sanction check searches for contractors or providers that are on the OIG exclusion list for reasons such as:
- Patient abuse or neglect
- A conviction of Medicare or Medicaid fraud
- A conviction of financial misconduct such as healthcare-related fraud or theft
- A conviction of unlawfully manufacturing, distributing, dispensing, or prescribing controlled substances
The OIG has discretion to exclude individuals for other reasons, including suspended or revoked licenses, misdemeanor convictions of healthcare-related fraud, and participating in unlawful kickback arrangements.
An OIG sanction check may be conducted by manually searching the online database or partnering with a third-party provider, like Checkr, for a comprehensive sanctions search.
How often should I check the OIG exclusion list?
In addition to checking the OIG exclusion list before hiring a job applicant, contractor, or vendor, the OIG recommends checking it at least monthly to verify individuals have not since been sanctioned. Employers can sign up to receive an email notification when the list is updated or use a consumer reporting agency (CRA), like Checkr, to more easily navigate ongoing healthcare sanctions screenings.
States are required to report healthcare sanctions and exclusions to the OIG, but there may be a lag time before the information is reported and appears on the OIG exclusion list. To ensure searches include the most accurate information, healthcare employers may wish to also search state-level sanction and exclusion lists.
What is an OIG background check?
An OIG background check is a type of sanction screening that searches the OIG exclusion list for mandatory or permissive exclusions that bar an individual from participation in federally funded healthcare programs. OIG background checks are often part of a more comprehensive healthcare sanctions check that may include other databases from federal and state sources.
OIG background checks are crucial for employers in the healthcare industry. Hiring individuals or organizations on the OIG exclusion list withdraws your organization’s eligibility for Medicare, Medicaid, and other federal healthcare programs and may result in substantial penalties and fines.
Run healthcare sanctions checks with Checkr
In addition to healthcare sanctions checks, employers must also comply with employment laws including the Fair Credit Reporting Act (FCRA) and Equal Employment Opportunity Commission (EEOC) guidance when using background screening information for hiring purposes. Given the complexity and risk involved, many companies choose to partner with an FCRA-compliant screening service, like Checkr, to conduct comprehensive and compliant healthcare sanctions background checks.
Checkr’s Fraud and Abuse Control Information Systems (FACIS) and Global Watchlist checks searches database records of adverse actions against individuals and entities in the healthcare field. These records may include disciplinary actions ranging from exclusions and debarments to letters of reprimand and probation. Our FACIS Level 1M and Global Watchlist screenings search the OIG exclusion list, SAM database, and available state Medicare and Medicaid data. You can also choose to search disciplinary action information from all the agencies in the FACIS database or select our FACIS healthcare sanctions Level 3 screenings to add more than 2,500 state sources of sanction and exclusion data.
Checkr's healthcare sanction checks meet federal requirements for health-care related screening, while our advanced platform delivers results with accuracy and speed. We enable you to make informed hiring decisions while simplifying compliance in a heavily-regulated industry. Get started today.
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Disclaimer
The resources provided here are for educational purposes only and do not constitute legal advice. We advise you to consult your own counsel if you have legal questions related to your specific practices and compliance with applicable laws.
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