Chief Compliance and Ethics Officer Health Care

Exclusion Screening as it applies to medical students

  • 1.  Exclusion Screening as it applies to medical students

    Posted 08-08-2019 12:18 PM
    ​We currently do exclusion screening on a monthly basis for employees and prior to hire for potential employees.  My question is whether we should also be doing exclusion screening for medical students we interview and then place on our rank list for our residency training program since we are committing to the first eight that match with us?

    Also, with regard to exclusion screening of vendors, at the HCCA conference, there was some discussion about whether we should also be screening the board members and employees of the vendor.  My take away was that if the vendor assigns a particular employee to work with us, we probably should conduct an exclusion screen.  Otherwise, no.  Did I understand this correctly?


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    Kelly Madcharo
    Compliance Officer
    Lincoln Medical Education Partnership
    Lincoln,NE
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    2019 HCCA Compliance Institute


  • 2.  RE: Exclusion Screening as it applies to medical students

    Posted 08-08-2019 12:47 PM
    I think you have your finger on it. There are the regulatory reasons for conducting exclusion checks and then there may be business reasons your organization may wish to consider. The regulatory risk you are mitigating is allowing excluded personnel to participate in Federal healthcare payment programs. At a minimum, I would think you would want to check the eight residents you pick up. Other considerations might be to incorporate the exclusion checking with the application for residency process, a signed acknowledgement from the students that clearly inform them how their residency would change if they are found to be excluded, and of course a documented policy/process.The residents could potentially still work for you in some capacity that does not touch on Federal healthcare payment programs, but your organization will need to define and enforce those segregated duties.

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    Chris Johnson
    Compliance Officer
    SyMed Corporation
    NAPA,CA
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    2019 HCCA Compliance Institute