Healthcare compliance is complicated. It's almost as if we're trying to solve a giant jigsaw puzzle where the parts are constantly changing. Two of the largest pieces of the puzzle involve staff exclusion screening and financial transparency.

First, let's take a closer look at the concepts of exclusion screening, the lists associated with screening, and the CMS open payment data to determine how they can be explained or defined in simpler terms.

The Reality of Exclusion Screening

Exclusion Screening is when you check to see if your employees and vendors have been excluded from working in the healthcare field through any of the Federal lists. However, to comply fully with the law, you need to check many more sources of information than just the Federal lists.

You can't just check one database to make sure someone is not excluded from working in the healthcare field. You need to check the OIG Exclusions List, SAM.gov (System for Award Management) and numerous state Medicaid exclusion lists. A nurse may be in good standing with the Texas Nurse Board, but could be excluded in the state of Louisiana. Not checking state exclusion lists leaves you without that crucial data.

This is a very data-intensive task. Manually cross-referencing a complete employee roster to over 40 federal and state exclusion databases is an overwhelming challenge. Venops makes it easy to do this in one streamlined process by aggregating all of these independent databases and files and allowing you to search them from a single interface in a manageable and accurate manner.

Why the Exclusions List OIG Matters Most

Although state exclusion lists are an important part of your due diligence process, the Excluded Individuals Entities list from CMS remains the primary source. This list identifies individuals who are barred from federally funded medical programs due to fraudulent actions, patient abuse, neglect, or defaulting on health profession student loans.

Hiring someone from the Excluded Individuals/Entities list means that any medical services they provide or order will be considered a "false claim," potentially exposing your practice to Civil Monetary Penalties that could put a small practice out of business.

The challenge lies in ensuring that you accurately identify the correct individual, as many names sound similar and social security numbers are sometimes not available as a resource. You will need to implement a system that is capable of verifying the records it locates against all available data to determine if "Yes, it is the same person" or "No, it's just a coincidence." Venops uses smart algorithms to provide you with reliable confirmation, so you aren’t chasing after ghosts.

Shedding Light with Open Payment CMS

which established the Open Payments CMS program. Open Payments CMS is a federal database which tracks the monetary and other types of payments from pharmaceutical/medical device manufacturers to medical doctors and teaching hospitals. If a physician receives any type of consulting fee's, travel reimbursement or an extravagant meal at the expense of a pharmaceutical manufacturer, it would be recorded on Open Payments under the name of the appropriate manufacturer.

You might wonder how this benefits your organization? The way this information benefits your organization is through the ability to monitor your physician's financial interests and the way those interests may potentially impact their prescribing behaviors and/or their research practices.

Monitoring the Open Payments CMS data provides your organization with the opportunity to identify possible conflicts of interest early; therefore, allowing your organization to continue to maintain transparency and ethical standards. However, like exclusion listing, the amount of data contained in the Open Payments CMS database is too large to analyze manually.

Bringing It All Together

Compliance is about seeing the whole picture. It is about ensuring that the doctor you hired isn't on an exclusion list and also knowing if they are receiving large sums of money from a vendor you use.

Trying to juggle Exclusion Screening and financial transparency monitoring using spreadsheets is a recipe for burnout. It is inefficient and prone to human error. Automation is the only way to scale this effectively.

Venops offers the technology to handle both the screening of bad actors and the monitoring of licenses and data. By centralizing your compliance efforts, you reduce the risk of fines and reputational damage.

Healthcare is complicated enough without having to worry about manual data entry. Whether you are navigating the Exclusions List OIG or reviewing financial data, the goal is simple: keep your organization clean, compliant, and focused on patient health. Venops is the partner that makes that goal achievable.

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