Title: Sanction Checking and Resolving Potential Matches
Date: March 21st, 2019
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Time: 1:00 PM EST
Educational Webinar Series: Relationship Risks in Healthcare Compliance
Sanction Checking and Resolving Potential Matches
Sanction checking is mandatory and requires considerable time, staff commitment, and cost as result of the number of databases to be searched, and frequency. The OIG calls for screening employees, physicians, vendors, and contractors against their List of Excluded Individuals and Entities (LEIE). CMS calls for screening against both the LEIE and GSA’s debarment listing, as well as calling on State Medicaid agencies to develop their own sanction databases and require monthly screening against it, along with LEIE and GSA. Other federal and state sanction databases impact on the health care provider sector, including those of DEA and FDA. The result has been significant increased burden greatly, not only for the compliance office but also human resources and procurement. Many healthcare providers now rely on vendor search engine tools to assist in sanction checking, however these tools address only a small part of the process. The bulk of the effort is investigating and resolving potential “hits,” and preparing a signed report to evidence it was all done appropriately. Failure to meet these standards may result in enforcement actions and impact on conditions of Medicare/Medicaid participation Hear from the experts who will address this subject and provide useful tips in meeting the challenge of effective sanction checking.
Learning Objectives include explaining:
Increases in screening burdens
Different sanction databases
Exclusions vs. Debarments
OIG position on enforcement
CMS enforcement role
Strategies to reduce burden
Best practices/checking tools
Methods to resolve potential “hits”
CLE credits are only offered for live attendance and are complimentary.
Jillian Bower Concepcion, MPA, CHC, CHPC,
Vice Presdidnent, Compliance Resource Center (CRC)
Strategic Management Services, LLC
Jillian Bower Concepcion (MPA, CHC, CHPC) is VP for the Compliance Resource Center (CRC) that provides comprehensive and integrated end-to-end compliance management tools, including Sanction Screening Services (S ) solutions and services. She has over 10 years experience as a compliance consultant, having provided advisory services to clients in the development, evaluation, and improvement of compliance programs. Ms. Concepcion has experience working with a variety of health care organizations, including health systems, physician practices, third-party billing companies, and managed care organizations. Ms. Concepcion works with organizations to implement CIA requirements, including development of the CIA implementation report, general and specific compliance training, policies and procedures and sanction screening process. She also leads client engagements involving compliance program development, implementation, evaluation, and remedial action to correct deficiencies.
Richard Kusserow, SMS CEO, previously served as DHHS Inspector General for 11 years that included issuing the Anti-Kickback Safe Harbors Rules and the passage and implementation of the Stark Laws. He has published 8 books and numerous journal articles related to healthcare compliance. He is regarded as an expert on those laws without peer. His firm of experts has assisted over 2,000 thousands of health care organizations with compliance advisory services. He has a compliance blog published by Wolters Kluwer.