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February 8, 2019

Transparency relies on real-time data. How to Close Gap 3 – The Time Lag Gap

Basing important decisions on inaccurate information exposes you and your patients to risk. Relying only on siloed data sets fraught with inherent time lags, lands you in the precarious gap of taking action on old, unverified, or yet-to-be published data.

Following are insights to consider when screening and verifying candidates, and monitoring your employee population as well as those with which you contract.

There are several reasons why the commonly used Federal data sources such as the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities (LEIE), the System of Award Management’s (SAM) Excluded Parties List System (EPLS); or independently curated lists such as the National Provider Data Bank (NPDB), and the published lists from the American Medical Association, and the Federation of State Medical Boards fall short in providing accurate data in a timely manner.

These data sets use the “push” model of data acquisition, meaning the publishers rely on sources to submit the data. In some cases, the provider is responsible to self-report infractions; in other cases, the place of employment, or the respective state medical board hold the responsibility to report to federal, state or independent data publishers. While state medical boards are required to report data, budget and administrative bandwidth constraints can restrict consistent and frequent reporting.

The time lag created by administrative protocol is different in every case. When there is positive intention to report adverse behavior, the lag due to procedural consideration creates a time lag gap. It is in this gap of good intentions where you could make a critical decision on inaccurate data and open the door to a problem. When deviant intention is at play, self-reporting adverse behavior is unlikely.

Another characteristic shared by these data publishers is the nature of the data itself. In the case of the OIG’s LEIE, there is no exclusion record on a licensed health care provider until the exclusion is issued and has completed the due process, which can take a year or longer.

The LEIE only lists those individuals and entities that are currently excluded from participation in Federal health care programs that include Medicare, Medicaid, CHIP and others. If you hire a person or engage with an entity on the LEIE, you may be subject to civil monetary penalties.

The exclusion process is governed by two sections—Federal, 1128 and State, 1156—of the Social Security Act. Ending up on the LEIE may start with an event or discovery of past behavior followed by an investigation, warnings, disciplinary actions, sanctions, board of director, and state board advisement.

If the conditions of Mandatory exclusions are met, then the OIG is required by law to exclude the individual or entity. In the event of Permissive exclusions, the OIG has discretion whether to exclude or not to exclude. Permissive exclusions are based on infractions that include submitting false or fraudulent claims to a Federal health care program, unlawful kickback arrangements, misdemeanor convictions related to a health care fraud other than Medicare or a State health care program, suspension, revocation, or surrender of a license based on professional competence, and the list goes on.

Once the individual or entity receives a Notice of Intent to Exclude (NOI), the person or entity can submit information for consideration, appeal to an HHS Administrative Law Judge, or to the HHS Departmental Appeals Board. Following a final decision by the appeals board, the decision can be moved to Judicial review in Federal court. This describes the stops along the way from an event, or discovery of behavior, to appearing on the LEIE, or not, depending on how much lenience is used in cases of Permissive exclusion.

The Time Lag Gap—that of sitting in risk on behalf of due process can be bridged by accessing Verisys’ proprietary data set, FACIS® containing eight million records matched to six million providers, in addition to Verisys’ exclusive data sets that are collected, verified, matched, and aggregated continuously within a highly secure platform run on cutting-edge technology. The data platform provides access to a national abuse registry, a practitioner license data set, Verified License Search and Status, (VLSS) of all jurisdictions and taxonomies, plus results from thousands of primary source publishers of civil, criminal and health care information.

Verisys connects through technology, as well as through human interaction by highly trained data experts, to more than 5,000 primary sources that include the OIG, LEIE, SAM, EPLS, FDA, DEA, FBI, U.S. DOJ, FHEP, and the U.S. Treasury Dept. Real-time data is pulled into the highly sophisticated platform on each respective source’s schedule ensuring that every record is current.

Then, each record is scientifically verified through proprietary algorithms, and is matched with 99.99 percent accuracy to the individual or entity to which that record belongs. The data is not only deep, as in full coverage from the thousands of primary source publishers, but also longitudinal, reaching back to 1992 when FACIS® was created.

This powerful data platform will show you in real time if a candidate or current employee was accused of elder abuse, or found guilty of fraud in the past week—as well as if a candidate has a 20-year history of surrendered licenses in numerous states.

We call this the 360-degree view of an individual or entity. There is more to know than if he/she/it is currently excluded. The choice to invite an individual to join your team, or schedule one of your doctors for a highly technical surgery should be made with careful consideration of the overall character and skillset of that individual. You should expect the full picture that might reveal prior patient deaths due to physician error or a propensity for dishonesty, violence, abuse, and fraud.

Each decision your organization makes across HR, credentialing, privileging, administration, marketing and legal with regard to hiring, promoting, retention, scheduling or engagement can now be based on data delivered in real time that is matched, verified, current and historical.

This data is delivered through the CheckMedic® platform and each MedPass® profile via dashboards, at-a-glance graphics, as well as full data reports, so leadership across the organizational chart can make decisions on actionable data. Enterprise-wide access to the same verified data is the fail-safe for flawless compliance and elevated best practices that mitigate the imposition of civil monetary penalties and fines, and most importantly, protect your patients, your staff, and your hard-earned reputation.

GAP 3 of “Achieving Transparency Through Closing 5 Critical Gaps in Credentialing” is brought to you by Verisys Corporation, creator of the most powerful health care data platform delivered by cutting-edge technology providing full transparency to your organization.

The e-book, “Closing the 5 Critical Gaps: A Guide to Understanding the Issues and Using Data Technology to Improve Provider Transparency to Protect Patients and Reduce Risk” is available to download here.

As an NCQA Certified and URAC Accredited Credentials Verification Organization, Verisys manages all data reports as a Consumer Reporting Agency abiding by federal law set forth in the Fair Credit Reporting Act. Verisys stores and exchanges data from a Tier 3+ secure environment, assures 99.99% identity resolution accuracy 99.99% of the time, and backs its promises with full indemnification.

Verisys earned and sustains compliance with two international quality standards, ISO 9001:2015, certified for quality of credentialing software and background screening; and, ISO 27001, certified for highest standards of information security and data protection.

The sum of these certifications and accreditations ensures that promises made are promises kept to the world’s highest standards.

Contact us for a demo of FACIS®, the industry standard of real-time data and discuss a staged rollout of screening, verifying and monitoring your entire workforce through CheckMedic® and the MedPass®.


Susen Sawatzki Written by Susen Sawatzki Healthcare Industry Expert Muse. Writer. Publisher. Producer. Creator of Inspiring Narratives. Connect with Susen on LinkedIn