Learn the best practices for an effective healthcare license monitoring program. Stay compliant with Joint Commission and accreditation standards, licensure board authorities, and OIG and CMS guidelines.
Tag: Sanction Screening
A comprehensive guide to healthcare license monitoring and verification.
Ever wonder if today is the day the Joint Commission shows up to begin its audit of your Human Resource compliance practices? How will you confidently demonstrate compliance with Joint Commission HR standards 01.02.01 with regard to staff qualifications and 01.02.05 with regard to verification of qualifications? For most people, this causes waves of panic and uncertainty. Will they find that you are compliant with your own internal requirement policies? Do your HR files contain all of the primary source documentation that your policy requires? Do you have a record of monthly OIG exclusion checks? Are you missing any key licenses, certificates, proof of MMR...? The list goes on and on. Failure of compliance in any one of these areas can result in the forced compliance of a CIA. But no need to panic. Educating your organization on how to implement best practices will result in an “audit-ready” compliance plan as well as avoiding any potential CIAs.
Healthcare has changed in so many ways in the last 25 years. I often think about how, if my grandfather(s) were alive today and practicing medicine, rather than in their lifetimes, how foreign the delivery of medicine would be to them. With the advances in technology, vaccines and even the cures that have been discovered for once deadly diseases, I am not sure if they could process all of the advancements. However, the one thing I know they would be astonished by would be how much healthcare delivery has been changed by increased regulation, fines and penalties, fraud and abuse, and even how medicine has evolved into a business. On the business side of medicine, I think they would particularly be struck by how in today's healthcare industry HR and Compliance are not so divided anymore. HR and Compliance work in conjunction with one another; the separation is not so black or white, tomato/tomahto, potato/potahto. Instead, they go hand in hand with one another. Specifically, compliance is a way of defining "proper" work behavior as well as outlining specific laws and policies. There are many thoughts and steps that have to go into it. In order for compliance to be successful, it has to start from the top and trickle its way down to all levels, educating and enlightening coworkers and employees on how to be compliant.
“An ounce of prevention is worth a pound of cure.” At least that is what Benjamin Franklin said a century ago. He is right, and that was insightful - even before his face would appear on U.S. currency. Little did he know how many “Benjamins” it would cost a healthcare company in fines for non-compliance with licenses.
Recently, the state of New Jersey ramped up its enforcement efforts by sanctioning 31 physicians for allegedly over-prescribing painkillers. This is a trend that seems to put a dent in the proliferation of addiction to pain killers, and the epidemic of pain killer narcotic over-prescription.
"The moment you meet a stranger, both of your brains are making thousands of computations at lightening speed to make major decision about one another," according to an article in Forbes. This only take seven seconds. It only takes seven seconds to make a first impression.
Cindy Daigle, Director of Compliance at U.S. Renal Care, shares her thoughts on hiring best practices. Compliance Team hiring practices plays into the long term success of the organization as well as driving the company’s compliance.
In order to provide medical care, one must be trained and educated, at a minimum. In certain cases, they must also be licensed and/or have a certification. Let's focus on physicians. Each state has a Medical Board and associated regulations surrounding the requirements to obtain and maintain a medical physician's license. In Ohio, the state law requires a medical practitioner who performs certain medical services to be licensed in Ohio. A recent Department of Justice case found several Ohio men to be liable for submitting false claims and for fraud when practicing medicine without a license in Ohio. Cecil Alexander Kent, Jr., pled guilty to one count of conspiracy to commit healthcare license fraud, two counts of healthcare fraud and five counts of making false statements relating to healthcare matters. Kent admitted in court while he was employed at B&M Visiting Doctors PLC., and while he was unlicensed in Ohio, he treated patients and falsified related patient records, including medical documents. He falsified prescriptions for controlled substances he wrote using the name and U.S. Drug Enforcement Administration number of a licensed physician.
How can a company protect itself from a fraudulent employee? For those of us who work in the healthcare industry, we all know how imperative and complicated healthcare licenses can be. Ensuring employee’s licenses are up to date and properly verified can be a headache for organizations industry-wide. Although organizations might think they are doing everything correctly and thoroughly, they could be terribly wrong. Errors in the healthcare license verification and tracking process is a very real possibility, especially in large companies that have thousands of employees and vendors. And yes, it is the company’s responsibility to verify all licenses and all other required documents.
Check out our license monitoring blog series: 1. Primary source verification - when, where & why2. Three common nuances in the healthcare license verification process3. Time Delays in Healthcare License Reporting to State Licensing Boards 4. Healthcare license fraud is a reality - here's how to avoid it Nurses help people. Nurses care. Nurses are to be trusted. So, would it surprise you that some people who practice as a nurse, are not actually nurses? As sad as it is, it happens. There are numerous cases each year where a person either claims to be a nurse and was never licensed, or who practices even though their license was revoked or suspended. Check out the OIG site to read about recent enforcement actions which include cases on fraudulent licenses. So how do you know if you have an employee who is not actually licensed? Here are 4 steps to combat healthcare license fraud and to ensure your staff is properly licensed and qualified through healthcare license verification:
This blog elaborates on the time delays in the reporting of disciplinary actions to state licensing boards and how those delays impact monthly monitoring of licenses for healthcare organizations. The differences in reporting between the states: Just like the reporting delay between the state Medicaid exclusion lists and the OIG, there can be delays in reporting disciplinary actions to the individual licensing boards. This happens for many reasons. The main reason for this delay is due to the inconsistency in how and when the states release and publish the minutes of the disciplinary actions by the board.
What is an OIG Sanction? A sanction issued by a state professional license board against an individual's license is an administrative action taken against an individual. Such sanction can be attributed to a restriction placed upon the license and can include a revocation of the license. These are also called disciplinary actions against the license. In order to locate a sanction or disclipinary action on a license, a search of the state professional license board minutes or actions must occur. Note: The term "Sanction" can be confusing as it also a term used to describe a disclipinary action against an individual's license. However, there is confusion in the marketplace because the OIG and SAM federal data sets refer to an Exclusion as a Sanction. For purposes of this blog, we are using the term Sanction to mean a disciplinary action taken against a person's license by a state professional license board.