Health Law Blog - Healthcare Legal Issues

Excluded Party Screening – Compliance Program Key Element

Screening For Excluded Providers
Key Elements Of Your Compliance Program

Most hospitals and larger healthcare organizations have gone through the process of developing compliance programs and are aware of the prohibitions against entering relationships with parties who have been excluded from a federal health care program.  Smaller organizations may not be aware of their responsibilities to screen all employees, vendors and contracting parties for exclusion.

Providers, such hospitals, medical groups, ambulatory surgery centers and home health agencies are subject to civil monetary penalties for submitting claims for healthcare items or services that are provided by excluded individuals or companies.  Fines can reach as high as $10,000 per item or service.  The fines can be astronomical if goods or services are regularly provided by the excluded party.

For this reason, compliance programs will generally include policies and procedures that require screening prior to contracting or employment.  Regular periodic screening is also highly recommended.  Smaller organizations and physician practices are at the most risk of violating these provisions.  These organizations have generally not yet faced the creation of formal compliance programs; although compliance programs will be mandatory in upcoming years.

 All health care providers must establish policies and procedures to be certain that they do not contract with excluded parties.

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John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

Tel 715.845.4336
Fax 715.845.2718

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