Verify Healthcare Certifications Correctly to Avoid Fines and Penalties

Sometimes healthcare certifications can take a back seat to licenses, but failure to remain compliant when it comes to verification and monitoring these credentials can have serious financial and even legal consequences. Let’s walk through some examples of where this process went wrong for a few organizations, and how you can be prepared to best process certifications for employees.

Types of Healthcare Certifications

A certification is a document issued by a third party organization for certain healthcare professionals signifying that they have met the minimum qualifications and tests to practice a technical job. Certifications play an important role in the healthcare ecosystem. There are many professions that issue a certification to a provider. Here are some examples of common positions that require certification.

• Ambulance Transport Services
• Dentists
• Dietitian/Nutritionists
• Kitchen Staff
• Mammography Technologists
• Nursing Assistants
• Pharmacy Technicians
• Physicians
• Poly Stenographers
• Radiologic Techs
• Speech Pathologists
• Surgical Technologists

Steps to Verify a Healthcare Certification

1. Ask to see the certificate.
2. Visually verify that it contains a name, number, issue date.
3. Determine that the issuer is the approved agency or certifying board in that state.
4. Determine if the issuer also can discipline or revoke the certificate.
5. Check the expiration date and set a reminder to verify on or before the expiration date.

But what happens if the certification expires? What are the possible penalties if the individual does not maintain his/her certification?

Here are two examples of companies that were fined for allowing a healthcare professional to work with an expired certification even though the certification was required in order to bill for services. Both of these cases were the result of a self-disclosure by the company to the Office of Inspector General (OIG). One reason for self-disclosure is to limit the financial penalty multiplier applied by the OIG for the submission of the false claim.

According to OIG, the Health Care Provider Self-Disclosure applies to healthcare providers, suppliers, or other individuals/entities subject to Civil Monetary Penalties. These parties may use the Provider Self-Disclosure Protocol (1998) to voluntarily disclose self-discovered evidence of potential fraud. Self-disclosure gives providers the opportunity to avoid the costs and disruptions associated with a government-directed investigation and civil or administrative litigation.

Volunteer Medical Services Corps of Lansdale

July 11, 2017

After it self-disclosed conduct to OIG, Volunteer Medical Services Corps of Lansdale (VMSCL), Pennsylvania, agreed to pay $26,795.70 for allegedly violating the Civil Monetary Penalties Law. OIG alleged that VMSCL staffed its ambulance transport services with an individual who had not maintained registrations of his Emergency Medical Technician certification with the appropriate state authority and then submitted claims and received payment from Federal healthcare programs for those transport services.

Colorado Fire Protection District

July 6, 2017

After it self-disclosed conduct to OIG, Arvada, Colorado Fire Protection District (AFPD), Colorado, agreed to pay $30,494.36 for allegedly violating the Civil Monetary Penalties Law. OIG alleged that AFPD staffed its ambulance transport services with two individuals whose paramedic certifications were expired and then submitted claims and received payment from Federal healthcare programs for these improperly staffed ambulance transport services.

Verifying Healthcare Certifications Across Departments

Remember that it is important to coordinate with HR and Credentialing when it comes to proper documentation of licenses and certifications. All too often, the process to capture, store and validate a credential such as a certification rests with multiple departments, and even are disbursed into the field to be managed by a nurse manager on a particular floor of a hospital.  This can create silos and make it harder to be audit ready. A best practice is to have one software-as-a-service platform to be the authoritative source or document of record for all things credential related.

Summary:  When it comes to your compliance program, it is important to include tracking and monitoring of licenses and certifications. Several job titles and state laws require that the professional not only have a license, but also a certificate. For example, it is imperative that a nurse not only have a state-issued license but also maintain an active Advanced Cardiac Life Support or CPR certificate in addition. Certifications play an important role in proper credentialing and documentation for compliance. Make sure you have one software-as-a-service platform to store, manage and verify these important documents. This will provide you with enterprise compliance, ensuring all of your professionals are properly licensed and credentialed and make sure you are audit ready when it comes to proper documentation of certifications.

Written by Michael Rosen, ESQ