Exclusion Monitoring: Does it really have to be that complicated?
There are two main federal Exclusion data sets and 33 state Medicaid Exclusion lists. As one might imagine, not all of them share data with each other, let alone to the OIG on a timely basis. In order to demonstrate the differences in searching and matching on these two divergent databases, it reminds us of choosing between the Android operating system and the Apple IOS X system; the functionality of the Samsung Galaxy 5 vs. the Apple Iphone…..(you get the picture).
Just like cellphones and operating systems, some federal data sets are easier than others to conduct, search, match and determine if a possible record matches your candidate or employee/vendor.
The SAM database is not one of them even though.
It was formed under a mandate from the Affordable Care Act in an attempt to create one broader dataset of individuals and entities that are debarred, sanctioned or excluded from doing business under a federal contract. The SAM site is the result of that effort.
It stands for the System for Award Management. The SAM dataset includes several federal contracting databases, but the most significant one for healthcare providers is the Government Services Administration’s list of Excluded Parties List System. (GSA-EPLS).
The other federal Exclusion list is the Office of Inspector General’s List of Excluded Individuals and Entities (OIG-LEIE). This list has been in existence since the early 1990’s and is a compilation of those persons and/or entities that have been excluded from participation in the federal healthcare dollar programs. The list was designed to include all exclusions across the country.
However, audits of the OIG show that it is missing up to 61% of exclusions at the state level. This blog will not address why or how; however, if you want to learn more about that we have blogged about it here.
Best way to search and match:
You need the last and first name of the individual, or the full name of the entity. Simply enter that data and if a possible name(s) are in the OIG-LEIE, you will be prompted to enter a Social Security Number for an individual to determine if it is a match. (A federal Employer Tax ID is not necessary to determine a match for an entity).
Pretty simple to use and quick to match a possible name. (www.sam.gov)
There are nine steps that need to be taken in order to search and match a possible record. It is important to note that exact punctuation and formatting is a factor when searching the SAM database. Here is an example:
Mr. Godfrey has been excluded by the OIG.
His address is 1625 St. Mary St. Apt 4 in Jackson, Mississippi.
But if you enter 1625 St. Mary Street #4 (notice the absence of "Apt."), you will find it. The address link is therefore too finicky to rely upon without additional searching.
In order to do that on SAM.gov, you will need to click as follows (on the left side of the search screen, for each person and entity):
- Performance Entity
- Entity Information (even if it is an individual)
- Individual name
- First Name
- Middle Name (if known- we recommend leaving this blank to get a broader search)
- Last Name
- Social Security Number
Although OIG-LEIE and SAM are two different federal exclusion lists, both should be searched each month.
Further, since there are gaps in reporting state Medicaid Exclusion data to the OIG-LEIE and the fact that the SAM.gov EPLS data is missing approximately 7% of state exclusion data on entities, a thorough search of the available 33 state Medicaid exclusion lists should also be performed each month.
No one said compliance was easy. However, it does make buying a phone seem like a piece of cake!
Written by Michael Rosen, ESQ
ProviderTrust Co-Founder, [email protected]
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as: Inc Magazine's Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year
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