Federal Program Eligibility Screening and Exclusion Disclosure
Federal Program Eligibility
Employing, engaging and contracting with persons classified as “ineligible” under Federal Program requirements is not allowed. Tenet has processes in place to ensure that individuals are screened against the Exclusion Lists before any part of the hiring, credentialing or contracting process starts. The screens are done monthly against the LEIE, EPLS and applicable state healthcare exclusion lists. The NPDB also is searched bi-annually for licensed physicians or allied healthcare practitioners. Sometimes an affidavit or representations and warranties stating that screening was completed is accepted but only for certain situations (e.g., students, contractors) and the documents must say that Tenet will be notified if anything changes.
- Background Screening Services and Corporate Compliance Department
- Conduct annual exclusions lists screenings
- List of Excluded Individuals/Entities (LEIE)
- Excluded Parties List (EPLS)
- Applicable state healthcare exclusion lists
- Ensure screened persons and entities are checked
- Employees
- Credentialed physicians
- Allied health practitioners
- Contracted staff and entities
- Temporary staff
- Vendors
- Shareholders
- Corporate officers and directors
- Medical Staff Department
- Conduct credentialing and re-credentialing checks
- National Practitioner Databank (NPDB)
- Searched bi-annually
- Ensure screened persons and entities are checked
- Credentialed and privileged medical staff
- Licensed physicians
- Allied healthcare practitioners
- Non-credentialed physicians
- Check before accepting a prescription or referral for items or services
- Screened Persons
- Inform supervisor, CO, CEO of any changes that may impact eligibility status such as:
- Debarment
- Exclusion
- Suspension
- Another event resulting in an Ineligible Person status
- Failure to notify may include any of the following:
- Disciplinary action up to and including suspension or termination
- Termination of a contract
- Other actions authorized by Tenet policies or Medical Staff Bylaws
- Facility Compliance Officer
- Evaluates potential compliance issues involving ineligible person with CCO
- Coordinates corrective action planning with Regional Compliance Officer and CCO
- Chief Compliance Officer
- Notifies reportable events to the OIG about Ineligible Persons
- Individual is an Ineligible Person
- Person is removed from any
- Responsibility or participation in providing services or business operations for Federally funded health care programs
- Position that their compensation or items or services provided, ordered or prescribed is paid in any part by Federally funded health care programs or funds
- Removal in place until person is reinstated to participate in the Federally funded health care programs
- Individual is Charged with Criminal Offense
- Actions to ensure and enact
- Responsibilities of that person has or will not adversely affect quality of care provided to any beneficiary, patient, resident
- Claims submitted to any Federally funded health care program are accurate
- Suspension, termination, termination of the contract or other actions authorized by Tenet policies or Medical Staff Bylaws
- Transporter convicted of patient neglect or abuse of former employment at a nursing home
- RN who surrendered her license to avoid charges and now works as a Unit Secretary
- Respiratory therapist whose license is on probationary status, due to a DUI charge
- Physical therapist who lost his license due to substance abuse issues
- Physician who defaulted on an HEAL student loan
- Biller who was convicted of embezzlement at another employer
- Patient Care Technician convicted of Medicaid fraud from prior occupation as ambulance driver
- Technician who prepares sterile surgical trays who previously surrendered her nursing license
- Payroll clerk who was convicted of misdemeanor drug possession
- Pharmacist who surrendered his license in one state and moved to another state
- RN hired by a previous owner of the hospital who since became excluded due to involvement in Medicaid fraud occurring at her second job where she works PRN
- Payment of salary by hospital to excluded RN who reviews treatment plans
- Payment of wages to PRN patient care technician who was excluded for conduct on previous job
- Payment of salary to excluded individuals who input prescription information for pharmacy billing
- Payment of salary to clerical or billing staff who are excluded due to loss of license or conduct that occurred at previous job
- Payment of equipment leasing fees to excluded medical device provider
- Payment of medical directorship fees to excluded physician
- Payment of fees to nurse staffing agency for provision of contract nurse who is excluded
- Filing claim for laboratory services provided pursuant to prescription from excluded physician
- Filing claim for radiology services ordered by excluded physician
- Filing cost report containing salary costs for excluded transcriptionist
- Follow up investigation is initiated by Background Screening Services and Corporate Compliance
- Additional documentation to support subject’s position may be provided by subject
- Sworn affidavit that subject is not the person found on the Exclusion Lists may be provided
- HR, Medical Staff Office or other departments sends any applicable documentation
- Copies of documentation are given to Facility Compliance Officer for review and input
- Follow up investigation completes
- Response to the individual is provided in a reasonable time-period
- Maintained by the Background Screening Services and Compliance
- Screening results filed (employee HR file, physician credentialing file, vendor contract file)
- Retained for minimum of 10 years after expiration or termination of employment, contract or privileges or 10 years after expiration of the CIA (whichever is later)
- Documents subject to audit by Audit Services or Corporate Compliance