Compassionate Care Hospice

Compassionate Care Hospice

INELIGIBLE PERSONS SCREENING

Policy No: 4026

PURPOSE

Federal law prohibits entities that participate in federal health care programs (including Medicare, Medicaid, and other governmental programs), such as Compassionate Care Hospice, from entering into or maintaining relationships with individuals or entities that have been excluded from participation in Federal health care programs. Also included are coverage for any item or service that has been ordered, supervised or furnished by an individual or entity during time when the individual or entity was excluded from the Federal program.

The purpose of this policy is to set forth procedures Compassionate Care Hospice follows in determining whether prospective and current employees, contractors and vendors (covered persons) are excluded to participate in Federal programs.

POLICY

Compassionate Care Hospice will perform pre-employment, monthly and annual exclusion reviews to ensure employees, vendors and contractors (covered persons) have not been sanctioned or excluded from participating in any federal health care program as prohibited by federal law.

For purposes of this policy, an “ineligible/ individual entity” is anyone who:

a)  Is currently excluded, debarred or otherwise ineligible to participate in the federal health care programs or in Federal procurement or non-procurement programs; or

b)  Has been convicted of a criminal offense that falls within the scope 42 U.S.C. §1320a -7 (a), but has not yet been excluded, debarred or suspended.

For purposes of this policy “exclusion lists” include:

a)  The HHS/OIG List of Excluded Individuals/Entities (LEIE) available through the internet at http://www.oig.hhs.gov

For the purpose of this policy “covered persons” include:

a)  All owners, officers, directors and employees of Compassionate Care Hospice; and

b)  All contractors, subcontractors, agents and other persons who provide patient care items or services or performs billing or coding functions on behalf of Compassionate Care Hospice excluding vendors whose sole connection is with selling or otherwise providing medical supplies or equipment to the organization who do not bill the Federal health care programs for such items

Effective / Reviewed / Revised
04-25-2015 / 07/01/2017

PROCEDURE:

Compassionate Care Hospice is responsible for the following screening procedures to ensure that prospective and all current covered persons are screened and are deemed eligible:

No employee may be hired unless the exclusion screens are complete.

SCREENING PRIOR TO HIRE

Human Resources will screen all potential employees by:

a)  Requiring applicants to disclose whether they are ineligible; and

b)  Screen against the HHS/OIG List of Excluded Individuals/Entities (LEIE).

c)  If any matches are found during the search, human resource is required to notify the legal department and Corporate Compliance office. If a potential employee is determined to be an excluded individual, the individual will be no longer eligible for hire.

d)  Screen all potential contractors, subcontractors, agents and vendors against the HHS/OIG List of Excluded Individuals/Entities (LEIE). If a potential contractor, subcontractor, vendor and agent is determined to be ineligible, the contract will not be implemented. Legal and Compliance office will be notified.

e)  Legal and compliance will follow directions regarding excluded individuals posted at the respective site.

ON HIRE

a)  After hire all employees are required to review the Standard of Conduct/ethical behavior and sign the acknowledgement of receipt of the policy, acknowledging that the employee has not been excluded, has no knowledge to an impending exclusion and agreement to notify the Compliance Office if they should become aware of potential exclusion.

MONTHLY

a)  All covered persons will be screened monthly against the HHS/OIG List of Excluded Individuals/Entities (LEIE) by a member of the compliance team.

b)  All CCH entities will be screened monthly against the General Services Administration’s System for Award management (SAM) by a member of the compliance department.

c)  If a covered person is determined to be ineligible, the Legal department will be notified.

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