Scaled Employee & Vendor Monitoring
Additional Monitoring & License Verification Services
All State Exclusion Lists
Ordering & Referring Physicians
OIG-LEIE & GSA's SAM.gov
All State Exclusion Lists
Annual Vendor Data Collection
Custom Vendor Questionnaires & Attestations
Vendor Data Maintenance
FDR Compliance
Integrated Payment Eligibility Status
Ongoing Vendor Owner & Vendor Employee Monitoring
OIG-LEIE & GSA's SAM.gov
All State Exclusion Lists
Basic Employee Monitoring
OIG-LEIE & GSA's SAM.gov
License Verification
Select State Exclusion Lists
Basic Vendor Monitoring
OIG-LEIE & GSA's SAM.gov
Select State Exclusion Lists
Impact Compliance™ Spectrum
Scaling up is key to more impactful compliance coverage.
Adding exclusion monitoring across all states ensures true visibility into potential risks due to bad actors or vendors moving from state to state. Plus, increasing your monitoring frequency ensures you have the most up-to-date information available. Increasing the frequency of license verifications also ensures that you identify any change in license status quickly, leading to better patient experiences and reducing organizational risk.
Ordering and referring physicians pose just as much risk as employed providers.
The OIG’s Special Advisory Bulletin gives ordering and referring physicians and employed or contracted providers equal weight. Yet, due to the challenges of gathering quality, complete data, most organizations verify ordering and referring physicians' data once and then allow it to become stagnant.
Gold-standard compliance monitoring programs combat this by culling their data on a semi-annual basis to include only active O&R physicians, then monitoring this group for exclusions just the same as they monitor the rest of their provider population.
Vendor data shouldn’t disappear into a black hole.
Vendor monitoring has long been considered an especially difficult piece of the compliance puzzle, and for good reason. Depending on their size, healthcare organizations may work with thousands of vendors across different sectors, and they’re responsible for verifying that each vendor is free from exclusions or sanctions. On top of this already-high volume of data, about 20% of vendor data changes each year—whether due to a name change, new TIN, or something else—making this population even harder to monitor.
Putting aside the inconsistent regulatory enforcement in this area, a lack of vendor compliance oversight leaves provider organizations—and the communities they serve—open to unnecessary risk of fraud, waste, and abuse.
The gold standard includes 360-degree visibility of all populations that pose a risk for fraud, waste, and abuse.
Regulations require exclusion monitoring of any individual who owns 5% or more of a vendor entity, yet vendor owners are typically the most frequently overlooked population of all. Even if you’re monitoring vendor entities for exclusions, you may be making payments to an excluded vendor owner without your knowledge. Ongoing monitoring of vendor entities, owners, and employees is the only way to gain total oversight of your vendor population’s compliance status.
as needed
annual
at hire
monthly
Additional Monitoring & License Verification Services
Regulatory requirements call for license and credential verification at hire and at expiration, which can leave a gap of several years without current oversight. An above-average compliance monitoring program includes more frequent—ideally monthly—credential monitoring to maintain visibility if a sanction, board action, or other issue should arise before the next expiration date.
It’s important to monitor state-level exclusion lists in the locations where you operate. But it’s equally as important to monitor all state exclusion lists to prevent any excluded individual or entity from slipping through the cracks simply by moving locations.
All State Exclusion Lists
Basic Vendor Monitoring
Though the regulations are clear, vendor monitoring remains a gray area for many healthcare organizations due to spotty enforcement. At a basic level, most organizations collect vendor data at onboarding without verification or attestation, and the data is often incomplete (for example, missing a TIN). These organizations verify that their vendors don’t appear on the OIG-LEIE or GSA’s SAM.gov, but they most likely only check state exclusion lists for the state(s) in which the organization operates.
At this level, organizations do not collect vendor owner data or keep up with their data hygiene, which allows excluded individuals or entities to go undetected while perpetuating fraud, waste, and abuse in the vendor space.
Basic Employee Monitoring
At this level, organizations meet regulatory requirements for employee monitoring. These organizations check the box by monitoring their employee population against federal exclusion lists (the OIG-LEIE and GSA’s SAM.gov) and some state exclusion lists—likely only the state(s) in which the organization operates. They also perform license verification for employees at hire and at expiration.
Though this approach meets minimum requirements, it leaves unnecessary blind spots that allow room for fraud, waste, and abuse to enter the organization’s ecosystem.
Vendor owners and employees can appear on federal exclusion lists, just the same as providers and vendor entities can. Eliminate your risk of working with an excluded individual or entity with ongoing monitoring of your entire population on a monthly basis.
OIG-LEIE & GSA's SAM.gov
Just like excluded providers, excluded vendor owners or employees can slide under the radar by moving states if healthcare organizations aren’t monitoring every available state exclusion list. Add ongoing monitoring of all state exclusion lists to complete your coverage.
All State Exclusion Lists
Just like the rest of your provider population, it’s important to monitor all state-level exclusion lists—not just the states in which you operate—on a monthly basis for your ordering and referring physicians.
All State Exclusion Lists
Protect your patients from excluded providers and your organization from Civil Monetary Penalties (CMPs) by monitoring your ordering and referring physicians for exclusions on a monthly basis.
OIG-LEIE & GSA's SAM.gov
Organizations have to know their vendors in order to make a meaningful impact on their risk level. That means collecting up-to-date vendor data and attestations on an annual basis, including taxpayer identification numbers (TINs) and vendor owner information. This process serves two purposes: first, it ensures that you have accurate vendor data, and second, it provides a natural timeline for updating your vendor database so that you’re not monitoring inactive vendors.
Custom Vendor Questionnaires & Attestations
Collecting accurate vendor data is the foundation for a comprehensive vendor compliance program, and maintaining good data hygiene is the next step. We’ve found that, on average, about 31% of vendors don’t have a valid TIN on file with the healthcare organizations they serve.
This kind of crucial oversight can be prevented with a more robust vendor data collection process, plus regular data maintenance to ensure that any changes are captured in your system of record.
Vendor Data Maintenance
First-tier, downstream, and related entities (FDRs) present a unique challenge in the vendor monitoring space. Though many organizations struggle to determine which vendors should be classified as FDRs in the first place, they’re required to monitor vendor owners and vendor employees for the FDRs that serve them.
In fact, Medicare Advantage plans are starting to require attestations that the organizations they contract with monitor the FDR population. This adds another layer of complexity that can be difficult to navigate without an experienced partner like ProviderTrust.
FDR Compliance
Weaving vendor data collection into the contracting and payment processes is the most effective way to lower the risk of making payments to an ineligible vendor. Plus, it’s a more concrete way to ensure that vendors supply the data you need in a timely manner.
We work with healthcare organizations to integrate a real-time compliance status into their AP system, meaning that only vendors whose data has been vetted will receive payments.
Integrated Payment Eligibility Status
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