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To: Human Resources Directors of Health Care Providers
Re: OIG Guidelines for
combating health care fraud and abuse
In order to combat health care fraud and abuse, the Office of Inspector General issued a document
in 1998 entitled "Compliance Program Guidance for Health care facility's". The
stated objective was to assist health care facility's to develop effective internal
controls and promote adherence to applicable federal and state laws. The document strongly
suggests that health care facilities adopt a compliance program that includes screening
standards.
The OIG Guidelines indicate that it is the health care facility's compliance officers
responsibility to coordinate with the Human Resources Department to ensure that the
National Practitioner Data Bank and Cumulative Sanction Report have been checked with
respect to all employees, medical staff, and independent contractors. (See CHA
Compliance Manual, App. A, Guidelines at pp. A 19-20) In addition, the OIG Guidelines
encourage to "regularly request information" from the monthly listing of
debarred contractors as part of their employee screening process.
Among other standards, the OIG indicated that an effective compliance program should
contain a number of components posing requirements on every health care facility. If the
OIG or the Department of Justice examines a facility's practices, it will consider whether
the facility's management has made reasonable efforts to detect and avoid fraud.
Therefore, it is imperative that all health care facilities adopt a compliance program.
The Office Of Inspector General recommends you:
- Conduct reasonable and prudent background investigations, including a reference check on
prospective employees.
- Background check to uncover any Medicare/Medicaid Fraud with respect to all employees,
medical staff, and independent contractors.
In answering the demand for help in this area, InfoLink has instituted a program to
provide health care facilities a search of the National Practitioner Data Bank, the
Cumulative Sanction Report and the Debarred Contractors List.
As I'm sure you are aware, the OIG Guidelines articulate screening standards that
health care facilities are expected to satisfy when evaluating job applicants including
disqualification rules that should be followed for incumbent employees. Therefore,
InfoLink will only report information from the listing established by the Health Care
Fraud and Abuse Data Collection Act of 1996. This data will be provided in a written
report to our clients in order to comply with OIG Guidelines. InfoLink however, shall only
take responsibility to report if your applicant, employee, or contractor is or is
not on the list. InfoLink is not responsible as to your use of the information.
In order to provide this service, InfoLink shall charge the following fees:
Search of the databases on a per name
basis
$11.80*
Includes search of all applicable databases for one flat fee:
Cumulative Sanction Report, Debarred Contractor Report, and The National Practitioner Data
Bank
(Subject to a $15.00 Minimum per order - i.e. you require only one name to be searched,
the charge would be $15; however, if you requested two names or more at the same time the
charge would be $11.80 each)
Discount Available to Search of the databases for all current employees
(minimum 100)
InfoLink is offering Members of the following Associations a 40%
discount when checking all current employee: Health Care Association of Southern
California, California Association of Health Services at Home, and the California Hospice
Association. All other health care providers who wish to search all current employees will
receive a 20% discount. To obtain this substantial discount,
clients will be invoiced 100% in advance.
*Does not include Access Fees charged InfoLink i.e.: The National Practitioner Data Bank
charges a $4 Access Fee)
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