EPStaffCheck™

Prevent Recoupments, Fines, and Penalties

The federal and state excluded provider programs affect every organization that receives federal or state money, whether for services rendered (patient care, Medicare, Medicaid), grant-funded programs, or other use of public dollars. Individuals and organizations who commit fraud, abuse, neglect to pay back certain federal student loans, and who commit other violations of federal and state law, are excluded from doing future business with the government. And hospitals and other organizations are not permitted to hire those individuals or entities to administer or provide services that are in any way reimbursed or paid for with public dollars. Repayments, fines and penalties for organizations who unknowingly hire such excluded parties can quickly reach tens or hundreds of thousands of dollars.

It is therefore critical that all healthcare providers and organizations that contract with government organizations or who provide services paid with public 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.

However, as organizations have discovered, checking multiple databases through manual web page searches is time-consuming for staff, error-prone, and leaves a limited audit trail (required to demonstrate good-faith compliance efforts and avoid penalties and fines).

EPStaffCheck™ is a low-cost, highly effective solution which will improve your compliance efforts, and reduce staff costs to perform these checks to only minutes per month. Our service monitors all the watchlists and reports back to you in one simple format, eliminating the need to track multiple sources and run multiple checks.

A subscription to EPStaffCheck is only $495/year and includes unlimited single-name checking as well as unlimited batch-list transactions. The base subscription includes the following national exclusion lists and options:

• OIG (Office of Inspector General)
• GSA EPLS (General Service Administration's Excluded Party List System)
• SDN (Specially Designated Nationals)
• Over 114 separate federal agencies -- see [list]
• PLUS! Add optional state-specific databases for only $130 each

To learn more about the OIG Exclusion Program, visit About the OIG

EPStaffCheck™ Makes Searching Easy:

• Perform individual checks instantly -- no waiting hours or days for results
• Create (or upload your own) staff and vendor lists and schedule periodic automatic batch checks of all staff and contractors
• Easily mark results that you have reviewed and cleared, so they do not appear again unless there is new sanction activity
• Flexible and easy to use, requiring no experience or special training
• Intelligent search technology ensures fewer false negatives to reduce staff review time, while still returning all relevant possible matches
• Detailed information on all possible matches for quick and easy review
• Documentation for all searches is generated print-ready for your records or to easily save to a file
• Makes annual or quarterly batch processing quick and easy (and much more likely to be done at all!)
• Automate your staff batch processing, and get weekly or monthly updates on all current staff, vendors, and employees

EPStaffCheck™ is Accurate and Up-to-Date:

• Searches data from over 114 federal government agencies containing over 118,000 entries for all persons or businesses who may be excluded from government-funded programs
• Add state-specific databases for your state if needed
• Database changes and updates are automatically performed daily, providing you with the most current information possible
• Easy data entry ensures fewer false negatives and false positives
• Possible matches include detailed information for your review

EPStaffCheck™ is a Web Application

• Accessible at any computer with a web connection, at any time, 24 hours/day, 7 days/week
• Prevent data loss and reinstallation of software; software and data is stored securely on our server and backed up daily
• No software installation, no need for data back-ups
• Unlimited user support, training, and technical assistance included in subscription price, toll-free, at no additional cost
• Access your data and search preferences through a secure, encrypted, password-protected system

FREE 14-DAY TRIAL

Interested? Want to take it for a no-obligation test drive? Sign up for a free 14-day trial of EPStaffCheck™ for your facility, including free support and training

EPStaffCheck Brochure

Download an EPStaffCheck brochure

Buy It Now

Purchase a subscription to EPStaffCheck or download an order form to mail or fax us with a check or approved purchase order

Pricing and Subscription Information

We don't believe in charging you for every check you perform in our system. We want to encourage facilities to perform checks on a regular basis, so that they are very quickly made aware of any potential exclusions - thus avoiding large repayments. In fact, we recommend that clients run at least a monthly batch check on all of their staff, providers, and contractors. Why? Because it takes no extra time to do it, and costs you nothing extra.

Annual subscription, per facility:

• $495 for unlimited transactions, unlimited shared users
• $130 per state database if required (optional)
• $300 per year for separate secure login accounts if required by separate sites or facilities or divisions

Frequently Asked Questions

What agencies does EPStaffCheck report on?

EPStaffCheck searches data from a multitude of government agencies containing over 118,000 entries for all persons or businesses who may be excluded from government-funded programs. (A list of most of the agencies appears at the bottom of this page.)

If an employee or contractor is listed as excluded, what do we need to do?

First, you need to verify that the employee or contractor really is a match to the results that were returned. You can do this with a social security match for some databases. If the person really is an excluded party, you need to immediately involve your Compliance Officer and/or Legal Department in researching the implications and steps necessary to become compliant and/or make repayments as necessary.

If we determine that we have contracted with an excluded individual for a short period of time and self-report, what kind of penalties can we expect?

Although there is no definite rule regarding such situations, previous settlements indicate that if a facility has a system for identifying excluded individuals, and identifies and self-reports a problem that is determined through such checking, that penalties are minimal. If the excluded individual was a physician who ordered or performed services, their may be recoupment for funds already received, but the penalty portion is typically mitigated by a facility who exercises a good faith effort to identify excluded individuals or entities.

What are the federal guidelines on determination of penalties?

The law provides for penalties of up to $10,000 for each item or service furnished, or each entry in a cost report, or other documentation used to support a claim for federal program (including state Medicaid program) reimbursement. The law also provides for an assessment of up to three times the amount claimed for each item or service. There is also a guideline that in most cases the amount of 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 review. To view recent OIG settlement summaries, visit Civil Monetary Penalties

Should we be verifying the criminal background on all employees and medical staff also? What about checking for bankruptcies and civil judgments?

You should only go to the effort and expense of gathering this information if you have a credentialing/employment process that will make use of this information. If you do not have a clear criteria for when and how such information should be evaluated, then trying to gather it will be expensive, time-consuming, and may lead to complaints of subjective evaluation, discrimination, restraint of trade, etc. You must have a clear, legally defensible policy if you wish to be more restrictive than that. As an example, to do a complete criminal background check, you must query each state's (and in some cases multiple jurisdiction within a state) records department. And if you receive records back (which are often not complete), you should have a clear policy on how to treat a DUI from 20 years ago, an arrest but no charges filed for domestic violence, and a bankruptcy from 2 years ago, and a justification for why such behavior is deemed relevant to their expected practice of medicine in your facility. If you collect information that you do not use, remember that such information could be used against you in a civil case (for example, a physician with a history of DUI is accused of committing malpractice while intoxicated, and an attorney argues that you had reason to know and greater obligation to monitor). Remember that as a general rule, if you ask for or use information, you are generally under an obligation to use such information in a consistent manner. Although this is a policy and legal issue for each facility to address, a good rule of thumb is not to collect information that you do not have a clear and objective policy for evaluating. Again, consult competent legal advice.

Does this replace the NPDB (National Practitioner Data Bank)?

No, you should still perform routine queries of the NPDB and the medical boards granting licensure.

We receive the exclusion information as an added subscription to our NPDB queries. Is there any reason to run EPStaffCheck also?

Although the NPDB offers an additional service to check exclusion information, the costs are approximately $3.25 per physician per year. EPStaffCheck is much more economical. Additionally, the NPDB does not offer exclusion checking for your non-practitioner employees, or for your vendors.

Do we need to check employees and vendors if they are not involved in direct patient care?

Yes. The prohibition against contracting with an excluded entity extends to administrative and/or management services that are not direct patient care, but that are a necessary component of the overall services being provided to federal program beneficiaries. Federal program funds include those received via claims submission, cost reports, fee schedules, pass-through costs and other payment systems that are ultimately funded at least in part by federal dollars.

Is there any legal way for us to employ or contract with an excluded party?

The only permissible way to conduct business with an excluded party is to establish a system to ensure that the items or services are paid for exclusively with private, non-federal funding sources, and that the items or services are related only to non-federal program patients. Such costs may not be included on cost reports or other similar documentation or requests for reimbursement. Please seek competent legal assistance in setting up such an agreement if it is truly necessary and cannot be avoided.

We have contracts with the USDA and the FDA. Our contracts require that we check all employees and vendors under the Exclusion Program. How do we know if these agencies are reported through EPStaffCheck?

EPStaffCheck verifies OIG, GSA, EPLS, and SDN listings. A [list] of all major government agencies who are included in EPStaffCheck reporting is below. Both of your contract agencies are included. If you don't see an agency listed, contact us and we can verify the current reporting status and availability of that agency. Additionally, state-specific listings are also available in states that maintain their own system.