How to Screen Your Non-Employed Provider Populations
With a growing number of contracted, referring, ordering, and prescribing physicians, you may interact with many providers who aren’t employees of your practice. Although these providers are not subject to your credentialing and privileging process, you are still responsible for verifying that these providers aren’t excluded at a state or federal level from providing services.
Mitigate Risk of HHS OIG Fines and Penalties
If you use the services of an excluded provider, you may be subject to penalties from the Office of the Inspector General (OIG) at Health and Human Services (HHS). You are expected to regularly perform the same checks against the exclusion list for non-employees as you are for your employed providers. To avoid fines and penalties, comprehensive monitoring of all providers is necessary. OIG does not send notifications of newly listed providers; rather, it expects health care entities to check the exclusion list regularly.
The exclusion list maintained by the OIG is called the List of Excluded Individuals and Entities (LEIE). This database can be downloaded, and providers should be verified against the list regularly — best practice is to check the database upon hiring and on a monthly basis. You will be held responsible if a provider you hire is on the exclusion list.
In addition to non-reimbursement of claims, hiring a provider on the exclusion list makes you subject to civil monetary penalties, whether you knew the provider was on the list or not.
What Information Does the Special Advisory Bulletin 2013 Provide?
The Special Advisory Bulletin of 2013 details the effects of exclusion from federal healthcare programs. It clarifies the responsibilities for healthcare entities to screen both employees and contractors, outlines the differences between the LEIE and other exclusion lists (such as SAM.gov), and explains circumstances under which providers may or may not use the services of excluded providers.
Can an Excluded Provider Refer a Patient to a Non-Excluded Provider?
An excluded provider may refer a patient to a non-excluded provider but beware. The conditions under which this is legal are strict. The excluded provider may not provide any services to the patient, including prescribing, ordering, or furnishing.
The non-excluded provider must treat the patient and bill state or federal healthcare programs completely independent of the excluded provider. If the non-excluded provider uses the services of the excluded provider to treat the patient in any way the provider can be held responsible. This includes providing items, services, and prescriptions.
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6 Tips for Screening and Monitoring Non-Employed Physicians
It’s a good idea to have a system in place for organizing your referral providers to make screening and monitoring easier. This is especially true if your practice relies heavily on referred procedures such as imaging, prescriptions, and laboratories. Here are a few tips:
- Keep a record of all your referring providers.
- Classify them by type of service and billing procedures.
- Determine who is responsible for monitoring providers and if these processes are sufficient to meet OIG guidelines. Determine where referral data is recorded.
- Determine how often new providers are used.
- Determine if data collected from new providers is sufficient for screening.
- Find out how often monitoring is conducted and determine if this time interval is sufficient to meet OIG guidelines.
4 Credentials to Verify for Every Non-Employed Provider
Even if a provider is on the LEIE list, it doesn’t mean they won’t have other credentials. To avoid liability, it’s important to check all of a physician’s credentials before using the services of a provider. Make sure the non-employed physician has all of the following:
- A current, unrestricted license
- Current verified credentials
- No exclusions from practice with Medicare/Medicaid programs
- Valid Drug Enforcement Agency (DEA) registration for prescriptions
How Augmented Data Helps You Screen Non-Employed Providers
When organizing provider data, using augmented data like the National Provider Identifier (NPI) and SSN helps create a smarter exclusion monitoring program. With the provider’s NPI number, you can check enrollment in national provider registries like NPPES. You can also use the NPI to screen against exclusion lists like LEIE, SAM.gov, and State Medicaid. By combining the provider’s NPI and SSN with your exclusion list search, you can avoid liability and fines and keep your patients safe.
Screening with FACIS®, is the most comprehensive data set for screening and monitoring healthcare providers, makes it easy to verify non-employed provider credentials not only against the OIG exclusion list but also against all federal and state data sources with real-time accuracy. Speak to a credentialing expert at Verisys to find out how you can ensure your non-employed providers’ credentials meet all government and regulatory standards.
|Written by Juliette Willard
Healthcare Communications Specialist
Being creative is my passion! Writer. Painter. Problem Solver. Optimist.
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