UW Medicine Compliance
Exclusion Screening – COMP.007
This policy establishes the standards by which UW Medicine screens all workforce members and vendors for restrictions on their ability to participate in federal and state healthcare programs and contracts.
This policy applies to all UW Medicine departments and operational units that perform exclusion screening.
Applicability: UW Medicine
Policy Title: Exclusion Screening
Policy Number: COMP.007
Superseded Policies: HMC, 135.4 Staff and Vendor Screening
NWH, Independent Contractor & Vendor Exclusion Screening
VMC, Employee, Independent Contractor and Vendor Screening Policy & Procedure
UWMC, 15-6 Employee Screening
UWMC, 15-14 Vendor Screening
UWP, C-015 Employee and Vendor Screening
Date Established: October 11, 2017
Date Effective: November 20, 2020
Next Review Date: November 20, 2023
UW Medicine does not hire, grant privileges to, contract with or bill for services rendered by the individuals and vendors who:
- Are excluded, debarred, suspended or otherwise declared ineligible to participate in federal healthcare programs or contracts;
- Have been convicted of a criminal offense as defined by 42 U.S.C. § 1320a-7(a) but have not been excluded, debarred, suspended or otherwise declared ineligible to participate in federal healthcare programs.
A. Prior to hiring or privileging/credentialing an individual or contracting with a vendor, UW Medicine screens the individual or organization against the applicable federal exclusion list(s), including:
- Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE); and
- U.S. General Service Administration (GSA) System for Award Management (SAM).
A. Subsequent to initial hiring, privileging/credentialing or contracting, exclusion screening is completed against the OIG and GSA exclusion lists: at the following intervals:
- Workforce members are screened monthly.
- Vendors are screened on a regular basis, and no less than semi-annually.
- Vendors determined to be a First Tier, Downstream or Related Entity (FDR) are screened monthly.
A. UW Medicine includes language in its contracts that require vendors to comply with the law to disclose information regarding exclusions from federal healthcare programs.
B. It is the responsibility of each workforce member and vendor to provide immediate notice to UW Medicine upon being (A) excluded, debarred, suspended or otherwise declared ineligible to participate in federal or state healthcare programs or contracts; (B) convicted of a criminal offense as defined by 42 U.S.C. § 1320a-7(a).
C. UW Medicine will notify health plan partners when sanctions or exclusions are discovered, within timelines indicated in the delegated service agreement.
A. If a workforce member or vendor has been excluded, debarred, suspended or otherwise declared ineligible to participate in federal healthcare programs or contracts or found to be convicted of a criminal offense as defined by 42 U.S.C. § 1320a-7(a), the appropriate UW Medicine departments are notified for further review and action, as needed. Actions may include the following:
- Immediate removal of the workforce member or vendor from direct or indirect responsibility for, or involvement in, any federal or state-funded healthcare program until (a) the issue is resolved and (b) it is determined the individual or vendor is not excluded, debarred, suspended or otherwise ineligible to participate in federal or state healthcare programs;
- Repayment of claims for services in which the excluded individual, to include workforce members, or vendor, participated;
- Suspension of privileges or termination of the workforce member consistent with the terms and conditions of employment and/or the privileging relationship; and/or
- Termination of the contract with the workforce member or vendor.
Appropriate documentation is maintained for the screening process and findings by the UW Medicine departments and operational units that perform exclusion screening for a period of 10 years per the UW Medicine Records Retention Schedule.
- UW Medicine Compliance Glossary.
- UWMC 75-18/HMC, Vendor Screening for Suppliers Including Consultants.
- ALNW, Pre-hire Background Checks.
- VMC, Vendor Credentialing.
- UWNC, Compl007 Employee Background Investigations and Sanction Screening.
- UWNC, Compl014 Vendor Screening.
- UW Medicine Records Retention Schedule
- United States Sentencing Commission, Guidelines Manual, §8B2.1 (Nov. 2016).
- Compliance Program Guidance for Hospitals, 63 Fed. Reg. 8987 (February 23, 1998).
- Supplemental Compliance Program Guidance for Hospitals, 70 Fed. Reg. 4858 (January 31, 2005).
- Exclusion of certain individuals and entities from participation in Medicare and State health care programs, 42 U.S.C. §1320a–7.
- Office of Inspector General. (May 8, 2013). Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs. Department of Health & Human Services.
- Centers for Medicare and Medicaid Services (CMS), Medicare Managed Care Manual, CMS Pub. 100-16, Chap. 21, Sec. 50.6.8 (Rev. 110, Jan. 11, 2013); available at https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/mc86c21.pdf.
- CMS, Medicare Prescription Benefit Manual, CMS Pub. 100-18, Chap. 9, Sec. 50.6.8 (Rev. 16, Jan. 11, 2013); available at https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/mc86c21.pdf.