In today’s regulatory environment, there are stringent rules not only dictating how you do business, but also surrounding who you can do business with. If your organization participates in Medicare or Medicaid programs, you are required to perform ongoing monitoring to ensure your vendors are not listed on any of the Federal or State exclusion lists.
Your company likely already performs ongoing exclusion checks on its employees, however the same Guidance from the Health and Human Services Office of Inspector General states you are required to do the same checks on your vendors. As a healthcare provider, you could be liable for severe fines for using Federal or State reimbursements to pay an excluded vendor.
In addition to monitoring vendor companies, the OIG has hinted in recent years at extending these requirements to include monitoring of any individual with a 5% or greater ownership interest of a vendor company. Not only does this complicate the process of ongoing monitoring, it creates an additional layer of data you must collect and maintain on your vendors.
Whether you manage this process internally or hire a third party company to manage exclusion monitoring, it should become a foundational step in your ongoing vendor credentialing process. Your liability extends far beyond the walls of your buildings, and can be costly if not properly managed.
Written by: Russ Cornwall, ProviderTrust Product and Client Support for VendorProof.
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