While exclusion monitoring certainly is not the primary purpose for your organization’s vendor database, the accuracy and completeness of the data is crucial for effective vendor compliance. Without complete and accurate vendor information, it is near impossible to be in compliance with the OIG’s guidance. At a minimum, we recommend that your vendor database contains ALL of the following data points for your vendors:
- Legal business name
- D/B/A (doing-business-as) name (if available)
- TIN (EIN for businesses/SSN for individuals/contractors)
- Physical address (note: often times mailing addresses are PO boxes, which are not as useful as street addresses)
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We recommend the following best practices for ensuring accurate and complete vendor data:
- Require a W9 from ALL new vendors. Many companies only require them from 1099 vendors, however the data captured on the W9 (Legal name, D/B/A name, TIN, physical address) is crucial to effective exclusion monitoring.
- Collect current W9s from your existing vendor population. This data can be used both to validate that what you currently have is accurate and to fill in missing data.
- Validate the data. We recommend using a TIN matching service to ensure that the legal name and TIN match the IRS’s records.
- Clean up the data. Most vendor databases are riddled with inactive & duplicate vendors. This makes exclusion monitoring a painful and expensive process!
- Monitor for Federal/State Medicare & Medicaid exclusions at least monthly. This ensures you are in compliance with the OIG’s guidance.
In our work, we see a broad spectrum when it comes to the quality of vendor data. If you’re already doing a lot of this – congratulations! You are ahead of the game! But if you are like most organizations, there is probably some room for improvement. When you are setting your 2017 goals & priorities, resolve to improve your vendor database. It might be a painful process in the short-term, but it will save you a lot of headache in the future. Happy New Year!
Russ Cornwall, Project Manager, VendorProof Application
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