Here at Vālenz Health®, we partner with many healthcare providers, facilities, and organizations to secure compliance with industry regulations, including those set by the Office of Inspector General (OIG).
In our decades of working with these clients, we’ve identified a few common errors and pitfalls holding these organizations back from full compliance — and exposing them to unnecessary legal and financial repercussions.
In today’s installment of our OIG compliance series, we highlight those risks, how they happen, and how you can learn from them to remain vigilant in your own OIG compliance monitoring processes.
Common OIG Compliance Risk Areas
In previous blog posts, we’ve covered at length what an OIG compliance program is and how to perform monthly compliance checks for your own healthcare organization.
As you optimize your OIG compliance process, we recommend keeping the following common pitfalls in mind, as they are the ones that most frequently cause headaches and challenges for our healthcare clients.
1. Not Searching all the Correct Sources
While compliance monitoring is often referred to in relation to the Office of Inspector General Exclusion List, the monitoring process shouldn’t be contained to that list alone. Similarly, healthcare organizations should not rely on single state-specific lists to identify compliance risks, even if that state is the only one in which they operate.
According to Section 6501 of the Affordable Care Act, if an individual or entity is sanctioned in one state, they are considered sanctioned in all states. Unfortunately, sanctions are not always applied to all state lists. By exclusively searching a single-state Medicaid, you may not be aware if an individual was previously sanctioned in another state, opening your organization up to unnecessary risks.
To minimize these risks, some states and contracts now require other non-standard databases to be checked in addition to OIG recommendations. Therefore, the best way to confirm compliance for your team and organization (and be prepared for a future audit) is to check every source you possibly can, as frequently as you can.
Compliance monitoring programs like Valenz Provider Staff Sanction Monitoring can make that happen with comprehensive sanction and exclusion list monitoring and non-compliance alerts.
2. Not Verifying Possible Matches
The OIG recommends that screening of employees and other relevant individuals is conducted on at least a monthly basis, but a once-a-month search may not be enough to properly identify and confirm potential matches with all sanction and exclusion lists.
Remember that exclusion lists like the System for Awards Management (SAM) may have minimal information on a potential match; relying solely on that information could lead to erroneous or missed matches. Therefore, when your organization is presented with a possible match from a program like Provider Staff Sanction Monitoring, we recommend taking additional steps to verify that match.
This process could be as simple as reviewing identifying information (such as a date of birth or a first/last name) to confirm or rule out a possible match based on the data you have available. At other times, you may need to visit the sanctioning agency’s website or reach out to their email contact to verify a possible match with more identifying information, such as a social security number.
3. Running Out of Date Batch Files
To successfully identify OIG compliance risks, you first need an accurate database to compare against.
When conducting your monthly checks, ensure that your batch files are up to date and reflect your current roster of employees/vendors/etc. If you’re using a program like Provider Staff Sanction Monitoring to automatically run checks on certain days of the month, you’ll need to ensure that you’re only running the files that you need to run to avoid unnecessary usage on your account.
4. Report Retention
As unpleasant as they are, compliance audits are a fact of life for healthcare organizations. To avoid unnecessary stress and wasted time and energy when they do appear, you should be proactively retaining your monthly reports in a clear, organized manner.
We recommend having a designated location for your compliance checks (both those done monthly and for individual providers) and ensuring reports are named and organized in a way that everything is easy to locate when needed.
Improve Your Compliance Monitoring Program
If your compliance monitoring program has stumbled into any of these pitfalls or other errors harming your ability to identify and resolve compliance concerns, there’s good news: These risks are easily resolved — and easy to avoid in the future with the right monitoring program.
Our Provider Staff Sanction Monitoring solution takes a proactive, automated approach to compliance monitoring to reduce these risks from occurring and deliver faster, more comprehensive identification of non-compliant healthcare providers.
Learn more about how the program works — and how Valenz can customize a solution for your unique organization needs — by contacting one of our team members today.
