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Why do I need to screen my employees for exclusions?

Screening employees for exclusions protects your organization from civil monetary penalties of thousands, if not millions of dollars. These penalties are levied by the OIG against organizations who employ excluded providers or vendors, while receiving payments through a federal health care program.

What is an OIG exclusion?

An exclusion is an action taken by the Department of Health and Human Services, Office of Inspector General (HHS OIG) that prohibits an individual or entity from participating in any health care program that receives federal funds.

What is the difference between a state and federal exclusion?

A federal exclusion is an action taken against an individual or entity by the OIG that excludes them from participating in Medicare and all other Federal health care programs. State exclusions are actions taken by individual states that prevent an individual or entity from receiving state Medicaid funds.

It’s important to note that not all state exclusions are reported to the OIG, so it’s beneficial to screen employees and vendors through all available federal and state exclusions lists.

Is it necessary for me to screen all of my contractors for exclusions?

Yes, the impact of an exclusion stretches beyond the individual or entity and is applicable to anyone who employs or contracts them while receiving government funds.

Should I only be concerned with screening employees or vendors who provide patient care?

Anyone can be excluded by the OIG, even the cashier at your local pharmacy, so it’s important to be proactive and screen all of your employees, not just those who provide patient care.

What is a state board sanction and why should I screen for them?

A state board sanction is a disciplinary action that’s taken against an individual by a state licensing board. The severity of a sanction ranges from placing the provider on probation to a complete revocation of their license.

Screening for state board sanctions ensures that you’re not employing unlicensed or disciplined providers that put your organization at risk for fines and liability.

Wouldn’t a provider be excluded by the OIG if they were sanctioned by a licensing board?

Not always. Sanctions are usually a result of some sort of professional misconduct which may or may not be severe enough to result in an exclusion.

What’s the impact on my organization if I employ a board sanctioned provider?

Employers are responsible for providing patients with safe, reliable care. Those who fail to monitor or take the appropriate action against health care providers who have received a board sanction are fostering an environment that puts patients at risk, which can result in criminal and civil liabilities.

How can I screen my employees and vendors for exclusions and board sanctions through Verisys?

Employees and vendors are submitted through a FACIS® (Fraud and Abuse Control Information System) search, which screens them against thousands of disciplinary records collected from primary sources, on health care providers who have had an adverse action taken against them by a federal or state government regulatory body or state-licensing board.

What credentialing services are offered by Verisys?

Verisys credentials Medical providers through CheckMedic, which is a paperless, web-based solution that includes a verified and secure MedPass for each provider.

Why should I use CheckMedic instead of other credentialing services?

CheckMedic creates a verified and secure MedPass for providers that contains all of their credentials that can be managed and updated as needed, with the additional benefit of having the credentialing data continuously monitored.

Do I have access to any of the other products and services offered by Verisys if I use CheckMedic?

Yes. In fact, the continuous monitoring of the credentialing data occurs through FACIS® and License Verifications, which adds the extra benefit of ensuring that providers aren’t excluded and that their licenses continue to be in good standing.

What credentials and information are included on a MedPass?

MedPasses contain all of the credentials and information needed by a medical staff, insurance company, or employer including:

• Education and Training*
Medical/Osteopathic School
Board Certifications
Special Certificates

• Experience*
Peer reference contacts

• Licenses and Registrations*

• Other*
Health and all other required disclosures
Liability coverage
Professional associations
Awards and commendations

• Reported Actions/FACIS level 3
Exclusions, Sanctions and Disbarments

• ProviderCheck

• Verisys can be your agent for NPDB

*Primary Source Verified with dates where required

Are verifications included in all of my FACIS® searches?

No, verifications aren’t automatically included in FACIS® searches unless they’re requested upon submission, however, they can be added to an initial search within seven business days after results are returned.

When are verifications performed?

Verifications are recommended when a candidate search returns multiple FACIS® records that are considered probable matches.

How are verifications performed?

Our experienced analysts conduct extensive research on the candidate and the FACIS® provider by gathering as much information as they can through primary sources to rule out or verify potential matches.

How accurate are the verifications performed by Verisys and can I trust the results?

Verisys is a Certified Verification Organization (CVO) and is fully certified by the NCQA for 10 out of 10 verification services. Our verifications are performed by a team of specially trained analysts who have an accuracy rate of more than 99%.

What type of results should I expect when a verification is performed?

Records are returned as either confirmed matches or non-matches. However, sometimes Verisys reports records as Unable To Determine (UTD). This usually occurs as a result of insufficient data provided for the individual or entity being searched or insufficient primary source data from the FACIS® record.

What information is returned for a verification that is a confirmed match?

Confirmed matches show whether or not the FACIS® record is current or historical, a description of how the verification was performed, a pdf copy of the original action, as well as a copy of the provider’s license if the action was taken by a state licensing board.

What is monitoring and how is it helpful to me?

Monitoring is an automated process offered by Verisys that screens employees and vendors for exclusions, debarments, and board disciplinary actions through FACIS® on an ongoing basis. This fulfills the recommendation of frequently screening employees and vendors for exclusions by the OIG and the Centers for Medicare & Medicaid Services (CMS).

Should I monitor my employees’ licenses and certifications?

Yes, employers can be held civilly and criminally liable if they facilitate unsafe patient care by employing health care professionals who have been sanctioned by a state licensing board due to unprofessional conduct.

Monitoring provides updated information on license statuses. This ensures that your employees are qualified and in good standing to practice medicine.

Which Verisys products can be used to monitor my employees and vendors?

FACIS®, License Searches, Verified License Searches, the Abuse Registry, and the Sex Offender Registry.

What is FACIS®

FACIS® (Fraud and Abuse Control Information System) is a database maintained by Verisys that is comprised of current and historical records on health care providers, individuals and entities who have been sanctioned, debarred, excluded, or disciplined by federal or state government regulatory bodies and state-level licensing boards.

What do the various levels of FACIS® mean and which level is recommended for monitoring?

FACIS® Levels

FACIS® is separated into four levels that allow you to screen employees and vendors against different primary sources for exclusions, debarments, sanctions, and disciplinary actions.

FACIS® Level 1 meets the federal government’s minimum requirements as outlined in the OIG’s Compliance Program Guidance and includes: OIG, GSA, DEA, FDA, PHS, ORI, TRICARE and OFAC-SDN data (federal only) and Medicare Opt-Out.

FACIS® Level 1M is the recommended baseline and minimally required compliance search for candidates employed by organizations receiving government funding and includes: FACIS® Level 1 plus State Medicaid sanctions, 42 HEAT sources and 51 AG Notice and Release sources, and state-level procurement/contractor debarment sources.

FACIS® Level 2 brings into focus a specified state and includes: FACIS® Level 1 / 1M as well as additional state-level board / source information for one specified state.

FACIS® Level 3 is the gold standard of sanction and exclusionary searches. It includes: All sources included in FACIS 1 / 1M / 2 and the sanctioning boards from all 56 U.S. jurisdictions across all provider types. This accesses more than 3,000 sources.

At a minimum, FACIS® Level 1M, satisfies the recommendations set forth by the OIG and CMS by screening employees for federal and state exclusions and debarments, however many of our clients feel that the best practice is to take a more assertive approach by monitoring employees through FACIS® Level 3, because it protects them from the potential negative ramifications of employing individuals or vendors who are sanctioned by a state-level licensing board.

What monitoring options are available for my existing population of employees, vendors, and contractors?

Verisys can monitor your populations annually, semi-annually, quarterly, monthly, or even continuously which reviews your population daily for any new data that’s retrieved from a primary source.

How do I submit my population data to Verisys for monitoring?

Population data needs to be entered into a .CSV (Comma Separated Values) template that’s provided by Verisys, then submitted through or through our SFTP (Secure File Transfer Protocol) site. We also offer several API integrations which can accept data and return results.

Still Have Questions?

We are thrilled to answer any questions you have about Verisys and the ways we can help your company with compliance, screening, verifications, credentialing and monitoring. We are also ready to answer questions you may have about the health care industry’s rules of compliance, what’s trending, and market changes that may alter the compliance landscape once again.