Exclusion Screening

The Importance of Sanction Screening


Emptech's founder, Jeff Aleixo


Jeffrey Aleixo


Regular screening of all individuals and entities for sanctions and exclusions is imperative for every healthcare organization, as a key component of an effective compliance program. Federal sanctions are created to control individuals and entities involved in harmful practices and penalize healthcare organizations that employ sanctioned parties. The purpose of sanction screening is to determine if an individual or entity is excluded from participating in federal health care programs. Thus, organizations need to monitor state and federal exclusion databases to avoid the risks associated with hiring or working with excluded individuals or entities.

What Is Sanction Screening

According to the Department of Health and Human Services Office of Inspector General (OIG), healthcare providers need to perform regular sanction screening of all employees, vendors, contractors, new hires, physicians, and volunteers to determine if any individuals or entities are excluded from participating in federal healthcare programs. The sanction screening process involves collecting names and identifying information from these parties, such as first, middle, and last names, Social Security Number, date of birth, or provider license number, and screening them against the names and information of excluded individuals or entities included in state and federal exclusion databases, such as the OIG List of Excluded Individuals and Entities (LEIE), the GSA System for Award Management, and state Medicaid lists.

Individuals or entities listed on any federal and state exclusion databases are involved in some kind of illegal or unethical misconduct and, therefore, should not work at any healthcare organization. Utilizing sanction screening to identify and address excluded individuals and entities is crucial for healthcare organizations to ensure a safe workplace. This also prevents instances of fraud, waste, abuse, or other unethical behavior that can easily become liabilities for the organization.

According to the OIG, it is the responsibility of healthcare providers to conduct regular sanction screening. Use this comprehensive guide to find out what steps to take in order to meet federal and state requirements and avoid penalties.

Minimizing Compliance Risks with Sanction Screening

A sanction is usually an early indicator of potential exclusion and its consequences vary depending on the severity of the incident. Approximately 50% of excluded providers on the LEIE are derived from their license being sanctioned. Once an individual or entity is excluded in one state, they are considered excluded in all states and not permitted to participate in federal healthcare funds. Therefore, sanction screening is a critical component of healthcare compliance that can help providers avoid severe consequences.

Conducting pre-hire screening is one of the most effective sanctions screening methods to make sure that individuals or entities are not on any exclusion lists. This way organizations can ensure that they are only hiring people who are not currently excluded, which also helps reduce the risks of engaging an individual or entity that cannot legally participate in federal health care programs. In addition to pre-hire screening, there are other measures organizations can undertake to ensure effective sanction screening, such as:

  • Screening every individual and entity associated with the healthcare organization, no matter if they are paid or unpaid. This includes employees, contracted businesses, vendors, suppliers, unpaid volunteers, and executive management.
  • Conducting sanction screening at least once a month. Federal and state exclusion lists are regularly updated to include new exclusions, as well as to remove exclusion records of individuals and entities that have been reinstated in federal health care programs. As a result, the lists change constantly.
  • Screening names against the OIG LEIE and the GSA System for Award Management list, together with state Medicaid lists as a minimum requirement.
  • Using sanctions screening software to obtain the most accurate and objective results and ensure compliance with federal and state requirements.

Outsourcing Sanction Screening

Sanctions screening is a critical component for successful healthcare compliance that needs to be performed accurately every time. However, it can present organizations with a number of challenges, such as how to input names and information to initiate the screening process, how often to screen, or how to follow up on any potential or positive matches of excluded individuals and entities. In addition to effectively tracking thousands of names that are being screened, healthcare organizations need to complete and maintain other workplace operations, which can be very hard to achieve.

On the other hand, exclusion and sanction screening software enable organizations to conduct screening more easily because they streamline the screening process through a centralized system that compares organizations’ data with federal and state databases. Automated sanction screening improves the accuracy and speed of the process while providing downloadable results and multiple search capabilities. As a result, healthcare organizations limit the number of individuals and entities involved in fraud, waste, or abuse and improve overall compliance.

Increasing Compliance and Accuracy

Effective sanctions screening is key for healthcare organizations to hire and keep only those individuals and entities who are not excluded from participating in federal health care programs due to involvement in fraud, waste, abuse, or other unethical behavior or actions. In order to efficiently screen their names, organizations need to have effective procedures in place for all stages of the screening process.  Furthermore, organizations can avoid compliance risks as well as other liabilities by using exclusion and sanction screening software. This allows healthcare organizations to improve the accuracy of the process, get organized results in downloadable format, and meet federal and state requirements. Ultimately, this leads to a safer work environment and a more effective compliance program, while benefiting healthcare organizations both short and long-term.


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