Are you doing business with providers, vendors, or employees who have been
excluded from Medicare or other government program participation?
LWEnSCheck Has Your Solution
LWEnSCheck allows you to verify that your
staff and other business relationships are not Medicare or State Excluded or
Sanctioned Individuals or Entities. Perform individual verifications as well as
batch lists. State-based exclusion, lists also available.
Monthly Exclusion Checks
The federal and state excluded provider programs affect every organization that
receives federal or state dollars, for medical and health services rendered,
social service funds, and grant programs. Excluded individuals may include those
who commit fraud or program abuse, who neglect to pay back certain federal
student loans, or who commit other violations of federal and state law, and as a
result are excluded from performing any work for federal or state programs.
Organizations are not permitted to hire those individuals to administer or
provide services that are in any way reimbursed or paid for with those public
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LWEnSCheck Client Agreement
Many states are now requiring and best
practices suggest that facilities recheck sanctions and exclusions on a monthly
basis. It is encouraged that facilities perform checks on a regular basis, so
that they are very quickly made aware of any potential exclusions, avoiding
large repayments. We agree that facilities should run at least a monthly batch
check on all of their staff, providers, and contractors. It takes no extra time
to do it, costs very little, and tells you what you need to know, when you need
to know it.
$125 per state sanction database (optional)
What are the federal
guidelines on penalties if we unknowingly hire an excluded individual?
The law provides for penalties of up to $10,000 for each item or service
furnished. The law also provides for up to three times the amount claimed for
each item or service. The rule of thumb is that the penalty should not be less
than twice the approximated amount of damages and costs sustained by the
government, including investigation costs, prosecution, and administrative case
It is therefore critical that all healthcare providers and organizations that
contract with government organizations or who receive state or federal dollars,
check all new-hires before employment. Organizations must also conduct periodic
follow-up checks of all employees, contractors, and medical staff to ensure that
no new exclusion activity is appearing for existing staff or vendors.
Is it difficult to do this
checking on our own? How often do we need to do it?
Monthly exclusion checks are becoming the norm and many State Medicaid Agencies
have their own exclusion databases. Organizations have discovered trying to
check multiple Federal and state databases through manual web page searches is
very time consuming and it does not provide a strong audit trail, which is
required to demonstrate a good-faith compliance effort.
Depending on what state you are in, you may be required to check all employees,
vendors, contractors, and referring providers at least monthly.
The average manual verification process takes 15-25 seconds for each employee
and vendor-- quickly adding up to hours or days of wasted staff time every
month. This manual process requires that you review the same results month
after month. LWEnSCheck reduces this time to minutes per month
What documentation should
we have in case of an audit?
An audit trail should provide written proof of all names searched, the date they
were initially searched and every subsequent date thereafter, the date each
database was updated, a list of all possible matches that were reviewed, and the
results of that review and the determination made.