NAVICENT HEALTH. Policy: Effective: Approval: OIG/GSA Exclusion Screening

Transcription

1 NAVICENT HEALTH Policy: Effective: Approval: SUBJECT: OIG/GSA Exclusion Screening SCOPE: This policy applies to all hospital employees, medical staff members, volunteers, contractors and agents (collectively Employees and Associates hereinafter). PURPOSE: Federal law prohibits entities such as Navicent Health that participate in Federal health care programs (including Medicare, Medicaid, and other governmental programs) from entering into or maintaining employment, medical staff and certain other relationships with individuals or entities that have been excluded from participation in Federal health care programs. The Medicare statute also excludes from coverage any item or service that has been ordered, supervised, or furnished by an individual or entity during time when the individual or entity has been excluded from the Federal health care program. The purpose of this policy is to set forth the procedures Navicent Health follows in determining whether potential and current Navicent Health Employees and Associates are excluded from participation in such Federal health care programs. The policy is also intended to facilitate compliance with requirements of the Corporate Integrity Agreement dated April 23, 2015 ( CIA hereinafter), between The Medical Center of Central Georgia ( MCCG hereinafter) and the United States Department of Health and Human Services Office of the Inspector General ( OIG hereinafter). Specifically, the CIA requires MCCG to ensure that all prospective and current Covered Persons are not Ineligible Persons, by implementing appropriate screening requirements. Policy Statement: Navicent Health will not employ, contract with, grant medical staff privileges to or otherwise affiliate with any individual or organization if the person or organization is known to be excluded from or otherwise ineligible to participation in Federal health care programs, or is known to have been convicted of an offense related to the provision of health care items and services, as described more fully at 42 U.S.C. 1320a-7(a). Employees and Associates of Navicent Health must notify Navicent Health immediately if they learn that they have been excluded from participation in Federal health care programs, including exclusion in another state s Medicaid program. This policy includes required procedures for performing initial, monthly and ongoing reviews of the Exclusion Lists to ensure that new and existing employees, medical staff members and contractors have not been sanctioned or excluded from participating in any Federal health care program. Each Navicent Health Employee or Associate who is responsible for establishing a relationship with an employee, medical staff member or contractor must assure that required screening procedures have been followed as the new relationship is established.

2 Page 2 If an Ineligible Person is identified, the Audit Services and Corporate Compliance Department ( ASCC ) must be contacted immediately for advice and direction on proceeding with an appropriate course of action. BACKGROUND: In addition to complying with Federal health care screening requirements, Navicent Health must comply with the specific obligations set forth by the CIA. The CIA requires that specific steps to be taken to promote compliance with the legal requirements related to screening. DEFINITIONS: 1. Federal health care programs include any plan or program that provides health benefits, whether directly, through insurance, or otherwise, which is funded directly, in whole or in part, by the United States Government. Federal health care programs include (without limitation), Medicare, Medicaid, managed Medicare/Medicaid, TriCare/VA/CHAMPUS, SCHIP, Federal Employees Health Benefit Plan, Indian Health Services, Health Services for Peace Corp Volunteers, Railroad Retirement Benefits, Black Lunch Program, Services Provided to Federal Prisoners, Pre-Existing Condition Insurance Plans (PCIPs) and Section 1011 Requests, and other federal health care programs identified in 42 C.F.R Covered Persons include: a. all owners, officers, directors, and employees of MCCG; b. all contractors, subcontractors, agents, and other persons who provide patient care items or services or who perform billing or coding functions on behalf of MCCG, excluding vendors whose sole connection with MCCG is selling or otherwise providing medical supplies or equipment to MCCG and who do not bill any Federal health care program for such medical supplies or equipment; and c. all physicians and other non-physician practitioners who are members of MCCG s active medical staff. Notwithstanding the above, this term does not include part-time or per diem employees, contractors, subcontractors, agents, and other persons who are not reasonably expected to work more than 160 hours during a Reporting Period, except that any such individuals shall become Covered Persons at the point when they work more than 160 hours during a Reporting Period. 3. Ineligible Persons include: a. an individual or entity who:

3 i. is currently excluded, debarred, suspended, or otherwise ineligible to participate in the Federal health care programs or in Federal procurement or non-procurement programs; or Page 3 ii. has been convicted of a criminal offense that falls within the scope of 42 U.S.C. 1320a-7(a), but has not yet been excluded, debarred, suspended, or otherwise declared ineligible. 4. Exclusion Lists include: a. the HHS/OIG List of Excluded Individuals/Entities (LEIE) (available through the Internet at and: b. the General Services Administration s System for Award Management (SAM) (available through the Internet at PROCEDURES: Screening will include reviewing the United States General Services Administration s System for Award Management (SAM) and the United States Department of Health and Human Services Office of Inspector General List of Excluded Individuals/Entities (LEIE). The following screening procedures will be conducted by various Navicent Health departments. 1. Human Resources Department A. Employee Screening Prior to Hire Human Resources will conduct screening against the Exclusion Lists (i.e., the LEIE and Sam lists) for all potential employees. Prior to hiring any Navicent Health employee, Human Resources will also require applicants to disclose whether they are an Ineligible Person. If a potential employee is determined to be an Ineligible Person, the individual will no longer be eligible for hire. 2. Medical Affairs Office A. Medical Staff Screening Prior to Privileges Being Granted i. The Medical Staff Office will screen all potential medical staff members using the National Practitioner Data Bank (NPDB), the American Medical Association Profile Service, and the Federation of State Medical Boards Credentials Verification to verify active licensure, negative actions against licensure, criminal records, and sanctions listed against the provider in the LEIE and SAM databases prior to granting privileged to any new medical staff applicant. The Medical Affairs Office will immediately notify ASCC of any potential or conclusive negative findings or potential or actual matches in the LEIE or SAM screening, prior to taking action to approve

4 Page 4 the Medical Staff application, and will work with the ASCC department to assure that Navicent Health responds appropriately to such negative findings or potential matches. 3. Legal Affairs/Contract Management Office A. Contractor/Vendor Screening (Named Party/Entity-Level) i. As part of the formal Contract Management process, the Legal Affairs/Contract Management Office will screen at the named party/entity-level all contracted Covered Persons prior to executing a contract, as well as during any review or renewal activities. ii. Screening of Employees of Contractors/Vendors 1. Contracts with Vendors whose employees or agents (including subcontractors and the employees or agents of sub-contractors) may individually meet the definition of a Covered Person or prospective Covered Person will either: a. include language obligating the Vendor to conduct screening of its employees pursuant to this policy and to maintain and/or provide ASCC with documentation of the same, or b. include language establishing an ongoing obligation for the Vendor to notify ASCC of each Covered Person or prospective Covered Person (who is expected to work 160 hours or more providing billing & coding or patient care services for Navicent Health) that they employ or have under contract. 2. ASCC will maintain a monitoring process to confirm that Vendors are meeting their contractual obligations to conduct and maintain documentation of Covered Person screening. 4. Audit Services and Corporate Compliance A. Monthly Re-Screening of Covered Persons i. ASCC will maintain a process for monthly rescreening of Covered Persons against the LEIE, and annual rescreening against the SAM databases. This monthly rescreening process will include (without limitation) rescreening of all employees, medical staff members, vendors and contractors, students, volunteers and of employees of contractors and vendors whose names have been provided to ASCC pursuant to Section 3.A.ii.1.b. of this policy.

5 Page 5 POLICY REVIEW RESPONSIBILITY Chief Compliance Officer 08/17/2015