Frequently Asked Questions

Pricing & Plans

What is the pricing for exclusion screening services for contractors and vendors?

Exclusion Screening offers transparent pricing starting at /month for exclusion screening services. Pricing is competitive and customized based on the specific monitoring lists and the volume of screenings required by your organization. For a personalized quote, visit the pricing page or contact the team directly.

How is the cost for exclusion screening determined?

The cost is determined by the specific monitoring lists you need to screen and the number of screenings required. This tailored approach ensures you only pay for what you need, making the service cost-effective and scalable for organizations of all sizes. For more details, visit the contact page.

Are there scalable pricing options for organizations with extensive vendor networks?

Yes, Exclusion Screening provides scalable pricing options that adapt to the needs of organizations with extensive vendor networks. The pricing model is designed to be affordable for small practices and scalable for large healthcare systems.

How can I get a quote for exclusion screening services?

You can request a personalized quote by filling out the form on the contact page. A screening specialist will reach out to demonstrate the solution and discuss pricing details.

Features & Capabilities

What features does Exclusion Screening offer for contractor and vendor screening?

Exclusion Screening provides comprehensive screening against federal and state exclusion databases, including OIG, SAM, and Medicaid lists. The proprietary SAFER™ software automates the process, offers daily updates, advanced algorithms to handle inconsistent data formats, and reduces false positives and negatives. Learn more on the vendor screening page.

Does Exclusion Screening support monthly screening for contractors and vendors?

Yes, Exclusion Screening supports monthly screening for contractors and vendors, as recommended by OIG guidance. This ensures ongoing compliance and reduces regulatory risks.

What is the SAFER™ software and how does it help with exclusion screening?

The SAFER™ software is Exclusion Screening's proprietary platform that automates exclusion screening, provides daily updates, uses advanced algorithms to handle inconsistent data formats and duplicate names, and reduces false positives and negatives. It is scalable for organizations of all sizes and eliminates manual effort.

Does Exclusion Screening offer a compliance hotline?

Yes, Exclusion Screening offers a secure and anonymous compliance hotline for reporting fraud, waste, and abuse. This feature fosters a culture of integrity and enables early detection of compliance issues. Learn more on the compliance hotline page.

Use Cases & Benefits

Who should use exclusion screening for contractors and vendors?

Healthcare providers, compliance officers, risk managers, legal teams, and operational managers responsible for regulatory compliance should use exclusion screening for contractors and vendors. Organizations with extensive vendor networks or high compliance risks benefit most from these services.

What are the main benefits of screening contractors and vendors?

Screening contractors and vendors helps organizations maintain compliance with federal and state regulations, reduces regulatory risks, avoids penalties such as Civil Monetary Penalties (CMP), and protects patient safety. It also ensures compliant business relationships and fosters a culture of integrity.

How does exclusion screening impact patient safety?

Exclusion screening ensures that contractors and vendors providing items or services integral to patient care are not excluded from federal or state programs, reducing the risk of harm to patients and supporting a safe healthcare environment.

Can exclusion screening help avoid financial penalties?

Yes, thorough exclusion screening helps organizations avoid significant financial penalties, such as Civil Monetary Penalties (CMP), by ensuring that excluded individuals or entities do not provide services payable by federal health care programs.

Product Information

What is exclusion screening for contractors and vendors?

Exclusion screening for contractors and vendors involves checking individuals and entities against federal and state exclusion lists to ensure they are not excluded from participating in federal health care programs. This is required for those providing items or services payable by such programs.

What guidance does OIG provide regarding exclusion screening?

The Office of Inspector General (OIG) requires exclusion screening of contractors and vendors who provide items or services payable by federal health care programs. The guidance emphasizes screening those integral to patient care and recommends monthly checks.

How should providers decide which contractors and vendors to screen?

Providers should use a framework that considers both the potential impact on patient safety and the relationship between the vendor or contractor and any claims made to federal health care programs. The closer a vendor is to patient care and claims, the more likely screening is necessary.

What types of services provided by contractors or vendors require exclusion screening?

Services integral to patient care or those directly or indirectly payable by federal health care programs require exclusion screening. Examples include agency nurses, physical therapists, and hazardous waste removal companies. Administrative, management, IT support, and even volunteer services may also require screening if related to claims.

Implementation & Support

How quickly can exclusion screening be implemented?

New clients can get started and begin screening within 1 day, which is faster than many other vendors. The SAFER™ software is designed for seamless integration and automates the process.

Is support available during the onboarding process?

Yes, Exclusion Screening provides dedicated support from compliance specialists to ensure a smooth and hassle-free setup for new clients.

How can I schedule a free consultation with Exclusion Screening?

You can schedule a free consultation by calling (800) 561-0798 or filling out the form on the website. A screening specialist will help assess which vendors and contractors need to be screened.

What resources are available to help understand exclusion screening requirements?

Exclusion Screening provides articles, guides, and reports such as the CMP Report and Screening Compliance Assessment. These resources help organizations understand exclusion screening requirements and best practices. Visit the resources page for more information.

Competition & Comparison

How does Exclusion Screening differ from other exclusion screening providers?

Exclusion Screening stands out due to its proprietary SAFER™ software, resolution-focused screening, daily updates, advanced algorithms, and expertise of former federal prosecutors. The company offers comprehensive services, cost-effective pricing, and scalable solutions for organizations of all sizes.

What are the unique strengths of Exclusion Screening compared to competitors?

Unique strengths include automation with SAFER™ software, resolution-focused screening, daily updates, advanced algorithms, cost-effectiveness, scalability, and legal expertise from former federal prosecutors. These features minimize compliance risks and streamline operations.

Is Exclusion Screening suitable for both small practices and large healthcare systems?

Yes, Exclusion Screening's services are designed to be affordable and scalable, making them suitable for small practices, large healthcare systems, and organizations with extensive vendor networks.

Does Exclusion Screening offer white label services?

Yes, Exclusion Screening offers white label services, allowing organizations to provide exclusion and sanction screening software under their own brand. Learn more on the White Label Services page.

Pain Points & Solutions

What compliance challenges do organizations face with contractor and vendor screening?

Organizations face challenges such as the complexity of compliance, manual screening inefficiencies, regulatory risks, fraud detection, cost-effectiveness, legal risks, and resource management. Exclusion Screening addresses these with automated processes, advanced algorithms, and comprehensive services.

How does Exclusion Screening solve the pain points of manual screening?

Exclusion Screening uses advanced algorithms and daily updates in its SAFER™ software to address inefficiencies such as inconsistent data formats, frequent database updates, and duplicate names, reducing the time and effort required for manual investigations.

How does Exclusion Screening help organizations avoid legal risks and penalties?

Resolution-focused screening confirms identities using multiple data points, helping organizations avoid penalties like Civil Monetary Penalties (CMP) by ensuring thorough and accurate exclusion checks.

How does Exclusion Screening address resource management challenges?

By automating the screening process with SAFER™ software, Exclusion Screening saves organizations significant time and resources, allowing them to focus on their core operations without the burden of compliance management.

Customer Proof & Case Studies

Are there any case studies demonstrating the impact of exclusion screening?

Yes, Exclusion Screening has a detailed case study on the impact of a False Claims Act judgment involving a Texas-based laboratory services company. The case highlights compliance challenges and the importance of thorough exclusion screening. Read the full case study here.

What industries are represented in Exclusion Screening's case studies?

The laboratory services industry is represented in Exclusion Screening's case studies. For additional case studies or information on other industries, contact Exclusion Screening directly.

How does exclusion screening help organizations avoid False Claims Act judgments?

Thorough exclusion screening prevents excluded individuals or entities from providing services payable by federal health care programs, reducing the risk of submitting false claims and facing legal judgments. The case study on a Texas laboratory company illustrates this impact.

Where can I find more information or case studies about exclusion screening?

Visit the Medicare Enforcement page or contact Exclusion Screening directly for more information and additional case studies.

New Report Screening Failures & Their Financial Fallout — $26M in penalties and how to avoid them. Download the report →

Exclusion Screening of Contractors and Vendors

By now, providers should be aware that the Office of Inspector General (OIG) requires exclusion screening of contractors and vendors, in addition to employees, if they provide items or services that are payable by Federal health care programs. This article identifies the OIG’s guidance on the issue, explains the difficulties it poses, and concludes by suggesting a framework for applying the guidance to screening vendors and contractors.

OIG Guidance: An Emphasis on Patient Care – A Focus on Payment

The OIG states that its emphasis on screening vendors and contractors for exclusions regards “items or services integral to the provision of patient care.”[2]This is sensible as many exclusions are the result of licensing issues and drug offenses which could result in a risk of harm to patients.

With that said, the OIG’s guidance focuses heavily on considering the nexus between vendor/contractor activities and any resulting claims. Providers are advised to review the “job category or contractual relationship” of each and every contractor and vendor. Then, if the provider determines that the vendor or contractor provides items or services payable “directly or indirectly, in whole or in part … by a Federal health care program,”[3] the vendor or contractor should be screened for exclusions monthly.

The Breadth of the Guidance

The OIG guidance is so broad that it is difficult to apply in a meaningful way. For instance, Exclusion Screening, LLC is sometimes asked by providers who make claims that include facility fees or some other overhead component whether they are obligated to screen contractors or vendors of such basic services as garbage collection and utilities out of a concern that they could be considered to be payable “indirectly” and at least “in part” by Medicare. While it is hard to believe that the OIG expects providers to screen the city’s sanitation service, the question raises a valid point.

While the guidance contains a number of examples that describe potentially problematic conduct when furnished by an excluded individual, the OIG seems to emphasize the broad scope of the screening obligation instead of providing a better understanding of it. For instance, the preparation of a surgical tray by an excluded person (who may not be in the operating theatre) and the inputting of information into a computer by an excluded person (who probably would not have written the prescription or participated in making the claim) are both identified as potentially problematic conduct. The guidance further states that virtually any service (administrative, management, IT support, etc.), even volunteer services, can trigger Civil Monetary Penalties (CMPs) if an excluded person provides the service unless the service is “wholly unrelated to Federal Health Care Programs.”

A Possible Framework for Applying the OIG Guidance[4]

Screening decisions based solely on whether the item or service provided was “wholly unrelated” to claims (or, stated another way, could possibly have contributed in some way to a claim) fail to recognize the OIG’s stated emphasis on services integral to patient care. In addition, it may also take a provider down a path that leads toward screening every conceivable vendor or contractor, including the city sanitation service as discussed above. As an alternative to this rigid (and unrealistic) approach, Exclusion Screening, LLC suggests using a framework that considers both the potential impact on patient safety of the activity in question, as well as the relationship between the vendor or contractor and any claims made to, or paid by, Federal Health Care programs. This is a sensible and workable approach that is consistent with the OIG’s dual priorities of patient safety and fiscal responsibility.

The framework would create a continuum of sorts, with contractors or vendors most closely associated with both patient care and claims on one end (such as an agency nurse or a physical therapist), and the vendors and contractors who have nothing to do with care and are only incidentally connected to reimbursement on the other (like the city garbage collection service). The closer a vendor or contractor is to the end that encompasses both patient care and claims (i.e., the nurse provided by a staffing company), the more likely it will be that the person or entity should be screened. Conversely, as one moves along the continuum to the other end, the necessity of screening decreases.

Though this may be an imperfect system that does not create bright lines, it specifically identifies and considers the factors important to the OIG. The continuum also gives context and focus to a provider’s screening decisions. By way of example, if one substitutes a hazardous waste collector for the city sanitation service and uses the continuum analysis, one can immediately see that the important considerations are (1) the risk a hazardous waste removal company and its employees pose to patient safety, and (2) the nexus between the hazardous waste removal service and reimbursement for the claim. Finally, and perhaps most importantly, since the framework is premised on the OIG’s principle concerns, using a framework helps make provider screening decisions defensible and supportable in the event of an audit.

Conclusion

The OIG’s guidance on exclusion screening of vendors and contractors is so broad that providers are left to draw their own lines and make their own decisions regarding whether or not to screen a specific individual or entity. In drawing these lines and making these decisions, Exclusion Screening, LLC believes providers are best served if they use a framework that incorporates both patient safety and financial considerations. Such a framework helps providers by giving analytic context to their decisions, demonstrating their commitment to compliance, and, ultimately, making their actions all the more defensible if subjected to scrutiny.

Call us at (800) 561-0798 or fill out the form below for a free assessment and consultation on which vendors and contractors need to be screened. 

Paul Weidenfeld is a co-founder of Exclusion Screening, LLC. A noted healthcare lawyer now in private practice, Paul frequently writes and speaks on issues relating to exclusions, fraud and abuse, and the False Claims Act. Before entering private practice, he was a federal health care fraud prosecutor for a number of years, and the Department of Justice Health Care Fraud Coordinator from 2005 – 2007.

Paul Weidenfeld is the author of this article. Contact Paul should you have any questions at: pweidenfeld@www.exclusionscreening.com or (800) 561-0798.


[1]   May 2013, Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs, Health and Human Services, Office of Inspector General, p. 16

[2]   Id. at p. 15

[3] Exclusion Screening, LLC is not a law firm and does not provide legal advice. As such, this is not intended, and should not be taken, as legal advice. We strongly recommend that you seek the advice of counsel whenever decisions that may have legal consequences are made.

Related Resources

Vendor Screening

Screen contractors and vendors against federal and state exclusion databases.

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Exclusion Screening

Screen employees and providers against over 42 federal and state exclusion databases.

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