The Medicaid/Medicare Sanction Screening Service mission is to provide Hospitals compliance with Federal and State Medicare and Medicaid payment regulations while generating evidence of due diligence that the compliance has been recurring and comprehensive.

This service is accomplished by taking a Hospital’s datasets of entities which require compliance screening and performing automated name association searches against Federal and State databases. Any positive matches resulting from the name association searches are then manually verified by investigators. The Investigators use personally identifying information such as Social Security Numbers, Medical License Numbers, Employer Identification Numbers, etc to verify that an entity is sanctioned against receiving Medicaid and/or Medicare payments.

In addition to the base service which Medicaid/Medicare Sanction Screening provides, each Hospital’s databases are audited for completeness. These databases include employees, physicians, physician service contract groups, vendors and vendor employees. The Medicaid/Medicare Sanction Screening Service identifies records which are missing key information necessary for verifying the identity of an entity being checked for sanctions. Typical examples of key information are Social Security Numbers, Employer Identification Numbers, Taxation Identification Numbers, etc. These records are identified, collected and returned to the Hospital for follow up action.

In addition to the base service which OIGManager™ provides, each Healthcare Facility databases are audited for completeness. These databases include employees, physicians, physician service contract groups, vendors and vendor employees.

The OIGManager™ Service identifies records which are missing key information necessary for verifying the identity of an entity being checked for sanctions. Typical examples of key information are Social Security Numbers, Employer Identification Numbers, Taxation Identification Numbers, etc. These records are identified, collected and returned to the Healthcare Facility for follow up action.

The OIGManager™ Service delivers reports back to the Healthcare Facility which collates and details the entities in their employ which are found to be sanctioned by a Federal and/or State agency against receiving Medicare and Medicaid payments.

The OIGManager™ Service generates these reports on a monthly basis with datasets submitted by the Healthcare Facility each month.

Fraud and Abuse Risk Areas

KEY QUESTION: What are Fraud and Abuse Risk Areas?

The most common risk areas associated with the delivery of quality health care to healthcare facility residents that frequently arises are; an enforcement case is resident safety, including provisions for investigation and reporting of instances of mistreatment, neglect and abuse, as well as mandated staff and vendor employee screening.

Vendors/Contractors

KEY QUESTION: Do Vendors/Contractors need to be screened?

All vendors and contracted agents are required to be screened for sanctions or exclusions through HHS / OIG and GSA listings. Sanction verification for current vendors and contractors will be checked against the OIG Cumulative Sanction Report, the GSA, and Department of Treasury Office of Foreign Assets Control (OFAC) exclusion listing of terrorism-sponsored organizations monthly.

Implementing an OIG Compliance Program

KEY QUESTION: What is the benefit to Evolution Consulting LLC implementing an OIG compliance program?

In addition to fulfilling its legal duty to ensure that it is not submitting false or inaccurate claims to Government and private payers, a healthcare facility may gain numerous other benefits by implementing a compliance program. The most important benefit would be through early detection and reporting, minimizing loss to the Government from false claims, and thereby reducing the healthcare facility’s exposure to civil damages and penalties, criminal sanctions, and administrative remedies.

Mandatory Exclusions

KEY QUESTION: Who cannot work at Our Healthcare facility?

Exclusion of certain individuals and entities from participation in Medicare and State health care programs Title 42 of the US Code as currently published by the US Government reflects the laws passed by Congress as of Jan. 3, 2007.

• Conviction of program-related crimes
• Conviction relating to patient abuse
• Felony conviction relating to health care fraud
• Felony conviction relating to controlled substance
• Conviction relating to obstruction of an investigation
• Misdemeanor conviction involving controlled substance
• License revocation or suspension
• Exclusion/suspension in Fed/State healthcare program
• Claims for excessive charges or unnecessary services
• Fraud, kickbacks, and other prohibited activities
• Entities controlled by a sanctioned individual
• Failure to disclose required information
• Failure to supply information/subcontractors/suppliers
• Failure to supply payment information
• Failure to grant immediate access
• Failure to take corrective action
• Default/health education loan/scholarship obligations
• Individuals controlling a sanctioned entity

Elements for an Effective Compliance Program

KEY QUESTION: What are the seven elements for healthcare facilities to be fundamental to an effective compliance program?

• Implementing written procedures/standards of conduct
• Designating a compliance officer/compliance committee
• Conducting effective training and education
• Developing effective lines of communication
• Enforcing standards through disciplinary guidelines
• Conducting internal monitoring and auditing
• Responding promptly to detected offenses and developing corrective action

Automated Processing: Easy, Bulk Data Processing of Employee/Vendor Records

KEY QUESTION: How do I get my health care provider’s data files easily and reliably to Evolution Consulting?

Evolution Consulting gives you the option of automating the process of transferring data files with employee/vendor data with a secure file server. Your companies IT department can easily connect to our Secure File Transfer Server and automate that connection and data transfer for regularly unattended data file uploads.

Comprehensive Sanction Screenings: Broad selection of Federal, State and local online resources

KEY QUESTION: What databases are queried with my employee/vendor data after submission to Evolution Consulting?

Evolution Consulting searches against all of the major publicly available Medicaid/Medicare databases. Databases are available at the local, State and Federal levels. These databases typically contain names, social security numbers, EINs, TINs for individuals that have been sanctioned from receiving Medicare and/or Medicaid payments.

Different Perspectives on Your Results: Aggregated and detailed reporting

KEY QUESTION: What kind of results can I expect from the sanction screening searches?

You will receive a timely, comprehensive report which will show the total number of records submitted to Evolution Consulting, the total number of records searched, the total number of records verified and the total number of records which returned a positive match. Any records which return a positive match will be detailed with that employee/vendor’s personal information and the sanctions against them. This report can be delivered to you electronically or you can fetch it from our Reporting Server.

Timeliness: Frequent, recurring record processing

KEY QUESTION: What is the schedule for submitting data records and receiving results?

Evolution Consulting prides itself on providing healthcare information when it’s needed most. Most State and Federal databases update their sanctioning information on a monthly basis, so we synchronize your records submissions to these updates.