Is Your Business at Risk? A Simple Guide to Exclusion and Vendor Screening

Trust is a huge part of both operating a business and managing a healthcare facility. You have trust that your employees are performing their jobs correctly. In addition, you trust your vendors to provide high-quality products. On the other hand, if you have an unreasonable level of trust and do not screen companies to do business with, you might be surprised if you hired a contractor that was banned from your industry or a vendor with a history of stealing from their customers.

The purpose of exclusion screening and vendor screening is to prevent surprises like this from happening. These concepts may sound like legal jargon, but they are actually just simple safety procedures or safety measures, such as locking your home at night.

What is Exclusion Screening? 

First, let’s talk about what an exclusion screening is. In almost every industry, federal/state governments produce an ‘exclusion list’ of individuals and organizations who have been excluded (banned) from taking part in federal government programs (such as Medicare, Medicaid etc) for past activities such as: fraud, patient abuse or defaulted student loans. 

Exclusion screening refers to the process of reviewing your employee and independent contractor databases against that exclusion list. It is a way to conduct ‘background checks’ specifically for people whose employers were specifically banned from working with them. 

You’ll be horrified to learn that hiring a person whose name appears on the exclusion list can have significa­ntly negative consequences to you as a business owner and manager. For example, the US Government can impose fines against your organization of THOUSANDS OF DOLLARS FOR EACH DAY that person worked for you. Additio­nally, the US Government may also require you to repay any and all payments made to your organization from government programs while that individual was working for you.

The Importance of Exclusions screening - When is it acceptable to refer to it by a "Plural": (Several Lists Changes)

The Exclusion Lists are continually updated so a provider may be in "good" status on one day; however, they may later be included on an exclusion list within a few short weeks after being listed. Therefore, it is not sufficient to only check on the employee's status when they are hired. Businesses should be checking these lists monthly to ensure that all people within their employ are legally present.

In addition to routine checks of employee Exclusions, it is also necessary to verify the Exclusions of outside firms as well (Vendor Checks).

Vendor checks are conducted on outside firms that provide services to your practice, such as: IT services; medical equipment; cleaning crews; staffing agencies, etc. A vendor may be classified as corrupt or financially unstable, which could result in the vendor disassociating from your business and jeopardizing the overall financial well-being of your business due to their Exclusions.

Vendor Screening involves a broader check. It answers questions like:

• Is this company a legitimate business?

• Are they on any government exclusion lists?

• Do they have a history of lawsuits or fraud?

• Are they financially stable enough to keep supplying us?

• 
  

If you skip this step, you risk "guilt by association." If your vendor commits fraud while working for you, your company could be held responsible or face a ruined reputation.

Ways to Make Screening Easier

It is a nightmare for small businesses to go through these lists by hand. There are many different databases of records available to state and federal government agencies that are very lengthy. Going through each name individually can take a great deal of time, and also leaves opportunity for human error (misspelled names).

Due to all the above reasons, most companies that are smart will use automated software to do both exclusion checking and vendor checking.

Automated software is set up to conduct checks against the entire list of employees and/or vendors and then compare that list against government databases. This is performed at least once a month. Any matches will result in immediate notification.

In Closing...

Compliance does not need to be scary! At the core of the issue, both Exclusion Checking and Vendor Checking are simply about knowing with whom you are dealing.

By verifying individuals with whom you are working, you are protecting not only your bottom line, but also your credibility and your customers or patients. This is a simple step to take that can help you have peace of mind while building a foundation of trust and safety!