Healthcare employers are responsible for searching sanction lists and databases as part of a complete medical background check—but your compliance obligations don’t end with pre-employment background screening. The Department of Health and Human Services (DHS) Office of Inspector General (OIG) requires healthcare employers to check the OIG exclusion list and sanction lists routinely for employee names.

Staying informed about the employment eligibility of individuals in your workforce helps you protect patients, employees, and visitors. Intermittent monitoring only provides information from one moment in time. To be sure you stay updated on employee healthcare sanctions, it’s essential to pursue continuous workforce monitoring.

What Is Continuous Monitoring?

Continuous workforce monitoring offers up-to-the-minute background screening capability for your workforce, so you can stay informed and take action where necessary. It provides you with ongoing updates about changes in employee license status as well as healthcare sanctions or exclusions within your workforce. Scanning technology monitors the following healthcare databases:

  • HHS OIG Exclusion List and Entities (LEIE): Lists individuals excluded from working for healthcare organizations that receive federal funding 
  • U.S. General Services Administration (GSA) System for Award Management (SAM): Lists individuals and firms barred from receiving federal contracts or subcontracts
  • U.S. Treasury Office of Foreign Asset Control (OFAC) database: Includes individuals from an embargoed country or region, and those who are prohibited from working or doing business in the US
  • State-specific exclusion resources, such as Ohio Medicaid, New York Office of the Medicaid Inspector General (OMIG), and California Medi-Cal 

Driven by smart automation technology, continuous monitoring integrates with your existing background screening framework and delivers the following features:

  • Immediate access to employee exclusion data and license updates
  • Tools for roster management and searching across employee population groups
  • Dashboards to view your workforce by monitoring status and action history

The Benefits of Continuous Monitoring

As one of the growing trends in background screening, continuous monitoring delivers more workforce visibility than using pre-hire background screening alone. Instead of finding out weeks or months after license activity or sanctions occur, continuous monitoring lets you know about the new activity as soon as updates appear on exclusion lists and databases. With a reliable workforce monitoring solution, you can achieve the following benefits:

Better regulatory compliance

To protect patients from harm, all healthcare organizations must comply with guidelines for national background checks established by the Centers for Medicare and Medicaid Services (CMS). In 2019, CMS announced a new rule to prevent hospitals and health systems from affiliating with individuals and entities convicted or suspected of committing fraud. Although a pre-hire background check can help your organization avoid hiring those individuals, continuous monitoring lets you know when there are changes impacting an employee’s ongoing employment eligibility.

When you have continuous monitoring in place, you have the tools to avoid the penalties associated with employing sanctioned or excluded employees, which can be costly. The DHS OIG, which imposes healthcare employment exclusions under the authority of the Social Security Act, can enforce civil monetary penalties in excess of $100,000 for employing an excluded person. One healthcare provider paid a $143,000 penalty for employing an individual who was excluded from participating in federal healthcare programs.

Ease of monitoring

If your organization has been conducting sanction tracking quarterly or even monthly, you know it can be a lengthy process. Internal tracking can be overly manual and prone to errors, and it can eat up valuable staff time. Even if you use a data management company to conduct searches, such companies only provide data, leaving you to take action on results.

Continuous monitoring software takes the manual element out of monitoring your workforce, and gives you information on recent sanction activity for follow-up where needed. Instead of conducting manual checks monthly or quarterly on a “batch” of employee names, you can rely on an automated process to do continuous checking for you. Once the software flags an issue, you can review the findings and determine next steps. Moreover, since continuous monitoring is one of many components of comprehensive background screening technology, you also have access to background screening specialists who can offer guidance and support where needed.

Real-time identification of healthcare sanctions

Given the lapse of time between when employee sanctions and exclusions occur and when they appear in various databases, intermittent sanction checks can keep you in the dark about new developments and possibly put patients or others at risk. For example, an employee sanction action on May 17 may not be reported in a sanction database until June 17. If you receive a monthly report on the 15th of each month, you may not find out about a May sanction until July. In the intervening time, the sanctioned employee is operating in your workplace and continuing to have access to patients. 

With continuous monitoring, you get notified as soon as the sanction appears in a database, not weeks or months after. Before, a delay in sanction reporting may have been unavoidable, but modern technology shrinks the window of time between sanction activity and notification.

Additional safeguard against workplace accidents and wrongdoing

In any healthcare environment, the safety and well-being of patients are paramount. According to a recent survey of hospital executives, healthcare leaders view patient safety as a top priority, but many believe they could make significant safety improvements. Continuous monitoring supports your efforts to improve patient safety by providing immediate updates of new sanction activity. Getting information sooner allows you to take action sooner.

When you have the tools and resources to quickly identify individuals who could pose a risk in the workplace, you can take action to prevent accidents or fraudulent acts. By taking a proactive approach to protecting the workplace, you’re doing more than ever to support patient safety.

Continuous Monitoring Helps Protect Your Workplace

Your organization has invested resources in screening, hiring, and developing your healthcare workforce, so you can deliver quality patient care and safety. By providing up-to-the-minute sanction updates, continuous monitoring adds another layer of protection to help you build a safer workplace. Monitoring software works around the clock, giving you the freedom to focus on other talent management activities.

CS SafeGuard by Corporate Screening helps you uncover disciplinary and administrative actions in real time, so you can stay in compliance and protect the workplace. Moreover, as a consumer reporting agency mandated by the FCRA, we also create a consumer report after identifying and verifying employee names. By replacing bulk database uploads, which only capture data from one moment in time, continuous monitoring gives you the peace of mind that comes with knowing your workforce is covered 24/7. Contact us to learn more and get a free trial of CS SafeGuard.Sign Up for a Free Trial