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What Risks/Challenges Should Be Considered

From a screening standpoint, the challenge with the central OIG and GSA databases is that they do not require participation and updates from all 50 states; there are currently 11 states that do not send any updates to the OIG/GSA lists. Any updates from these states would have to be obtained from those states directly. Considering that excluded individuals often move from one state to another to obtain new employment, it would be risky to depend solely on screening of the central OIG/GSA lists.

There are also other databases that would be prudent to screen to ensure adequate protection. These include the National Practitioners database, the OFAC Terrorist Watch List, the Fugitives list, Social Security Verification, and Homeland Security Verification. However, some of these databases are only accessible to licensed investigators, and not every health care institution has someone like this on its staff.

Implementation of a sanction screening compliance program also impacts an organization from a resource standpoint. The health care institution would require the setup of an IT system and methodology to manage screening of multiple, separate database sources (OIG, GSA, OFAC, 11 states, plus others), plus the human resources to compile and perform monthly database screens of current employees and new hires, as well as any vendor employees. Most health care organizations have dozens or even hundreds of vendors. And this is just for the screening process itself, and does not include the coordination of activities surrounding the full compliance program such as written policies, communication, training, validation of screening results, management of employment actions against sanctioned individuals, coordination with vendors, updates to regulations, auditing, and self-reporting of results to OIG (which must happen within 60 days of discovering any sanctions).

All health care institutions have as their number one value to protect the health and welfare of their patients. New regulations now require a more proactive effort to ensure that a safe and qualified workforce is rendering services in accordance with that value. Now is the time for all health care organizations to create robust OIG sanction screening compliance programs to keep patients safe and preserve the integrity of our healthcare system.