What Is a Healthcare Sanction?
In healthcare, “sanction” is a general term applied to a variety of disciplinary and administrative actions. It can be taken against an individual or a medical license.
Healthcare personnel can be sanctioned for a variety of reasons, including:
- Excluded individuals billing Medicare and/or Medicaid for items and/or services
- Patient abuse/neglect
- Defaulting on student loans
- Healthcare license revocation
- Misdemeanor affiliated with controlled substances
- Provider overprescribing drugs
- Committing healthcare fraud
Who Issues a Healthcare Sanction?
These actions can be taken by more than 3,000 licensing boards and entities across all 50 states, each with its own source documenting sanctions.
Sanctions can represent significant risks to a healthcare organization for compliance and patient safety.
How do you effectively screen against so many sanctions sources?
In order to avoid incurring hefty fines for hiring an excluded individual, it is your duty to screen everyone you are in business with against healthcare sanction data.
- According to the OIG, CMS Guidelines, and state Medicaid Bulletins or Directives, it is the responsibility of the employer to conduct monthly OIG exclusion monitoring. A sanction against an individual or a license can be an early indicator of an impending OIG or state exclusion. It is imperative to include frequent sanction checks in addition to OIG exclusion monthly monitoring in your compliance program.
- A nationwide search across all state licensing boards is a best practice to be certain to locate any past disciplinary actions taken against a prospective employee. Monitoring these sources on a continual basis during employment is crucial. Time after time individuals are hired, after moving from another state, with a disciplinary action in their previous state of residence. In some cases, the employee was hired before the disciplinary action in the other state was released. Complementing your background checks with ongoing OIG monitoring and comprehensive sanction screening brings these issues to light.
- Did you know: 40% of exclusions on the OIG List of Excluded Individuals and Entities (LEIE) are derived from a sanctioned or revoked license? Exclusions are a severe form of a sanction, ending with the OIG issuing an exclusion and therefore placing the individual or entity on the OIG exclusion list. This provider will be prohibited from participating in federal healthcare program (CMS) dollar reimbursements.
- The sanction screening process can leave HR and Compliance teams with what seems to be an insurmountable task of constant monitoring and uncertainty in the current status of the information.
