HomeMy WebLinkAboutMHIDDEI-417 Screening of Employees for Exclusion from Participation in Federal Health Care Programs1
FRANKLIN/FULTON COUNTY
MENTAL HEALTH/INTELLECTUAL & DEVELOPMENTAL
DISABILITIES/EARLY INTERVENTION
425 Franklin Farm Lane
Chambersburg, PA 17202
(717) 264-5387
MH/IDD/EI PROCEDURE STATEMENT
PROCEDURE SUBJECT: Screening of Employees for Exclusion from Participation in Federal
Health Care Programs
PROCEDURE NUMBER: MHIDDEI-417
Effective Date: January 1, 2012
Date Revised: December 12, 2019
References: MA Bulletin 99-11-05 Provider Screening of Employees and Contractors for
Exclusion from Participation in Federal Health Care Programs and the Effect of
Exclusion on Participation
INTRODUCTION:
To comply with MA regulations, all provider organizations will follow the above referenced MA
bulletin and verify that all employees and contractors “whose functions are a necessary
component of providing items and services to MA recipients and who are involved in generating
a claim to bill for services, or are paid by Medicaid (including salaries that are included on a cost
report submitted to the Department), …be screened for exclusion before employing and/or
contracting with them and, if hired, should be rescreened on an ongoing monthly basis.”
PROCEDURE:
All providers and contractors will check that staff is not excluded from the program using the
following databases prior to hire and on a monthly basis thereafter:
a. Pennsylvania Medicheck List: a database maintained by the Department that identifies
providers, individuals, and other entities that are precluded from participation in
Pennsylvania’s MA Program:
https://www.humanservices.state.pa.us/Medchk/MedchkSearch/Index
If an individual’s resume indicates that he/she has worked in another state, providers
should also check that state’s individual list.
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b. Office of Inspector General (OIG):database maintained by Health and Human Services
Office of Inspector General (HHSOIG) that identifies individuals or entities that have
been excluded nationwide from participation in any federal health care program. An
individual or entity included on the List of Excluded Individuals/Entities (LEIE) is
ineligible to participate, either directly or indirectly, in the MA Program. Although the
Department makes best efforts to include on the Medicheck List all federally excluded
individuals/entities that practice in Pennsylvania, providers must also use the LEIE to
ensure that the individual/entity is eligible to participate in the MA Program:
http://www.oig.hhs.gov/exclusions/index.asp
c. System for Award Management (SAM): SAM is a worldwide database maintained by
the General Services Administration (GSA) that provides information about parties that
are excluded from receiving Federal contracts, certain subcontracts, and certain Federal
financial and nonfinancial assistance and benefits: https://www.sam.gov/.
Franklin County Risk Management Department will check all MH/IDD/EI staff, contracted
providers and vendors on a monthly basis on the above three (3) sites as well as two (2)
additional sites: OIG, Most Wanted Fugitives (https://oig.hhs.gov/fraud/fugitives/) and Office of
Foreign Assets Control, Specially Designated Nationals (https://www.treasury.gov/resource-
center/sanctions/SDN-List/Pages/default.aspx).
In order to comply with the MA Bulletin, Providers must have a written process in place
identifying how they will comply with all aspects of the bulletin, including self-reports and self-
audits. This process will be reviewed by MH/IDD/EI at each provider’s annual monitoring.
PROCESS FOR MH/IDD/EI STAFF:
Franklin County Human Resources Department verifies applicable State and Federal exclusion
lists for every applicant prior to being hired and on a monthly basis for all current employees. As
per the County’s exclusion check policy.