Friday, June 20, 2014

Who’s the New Guy? Really?

The new hire…
Staffing is tight. You just worked an extra 16 hours this week to fill the holes in the schedule which looks like swiss cheese on paper.

In walks someone new that you never met. He (or she) sticks out his hand, shakes firmly and proceeds to explain that he has just moved to the area and once worked in walla-walla-somewhere as a provider and needs a job.

So, you run to the office, grab the application and tell your new friend to fill everything out.

“Shouldn’t be a problem,” you say. “Scan over a copy of your certifications and we’ll be back in touch with you in a day or two.”


Who are you?
Not so fast…
The new guy produces valid training and course completion certificates. By the end of the week, he’s hired. He orients well. He checks out with the medical director and you give him the green light to fill those holes on the next schedule.

Job well done, right? Well…not so fast.

One more check!
You may or may not have ever heard of this next step, but there’s one more check that you need to do to protect your department before the new guy can hit the street.

It’s time to access the Health and Human Services, Office of Inspector General’s “List of Excluded Individuals and Entities.”

The list is conveniently located online at http://oig.hhs.gov/exclusions


Once you have accessed the website, it’s all very simple. Enter the new hire’s name, first and last, and hit the “Search” button. The site will bring up any name match (or similar name match.)

If there’s a possible match, then the person doing the search can simply click on the “Verify” link next to the person’s name where the site will then ask you to enter the person’s Social Security Number. Once the SSN is entered the site then will either confirm a match or it will advise the person doing the search that there is a mismatch which indicates that while there was a hit on the name, it most likely was a different person (be sure to verify the SSN you used.)

“Why do I need to run this check?”
So by now you’re saying to yourself, “Why do I need to run this check?”

Just recently the HHS Office of Inspector General came out with a special bulletin reminder that this a vital step for any healthcare entity (ambulance departments included.) Employing any single person (even if they are a volunteer) who is on the exclusion list will result in both the requirement to refund any Medicare or Medicaid dollars paid to that entity during the time of the employment or volunteer involvement and possibly can result in civil monetary penalties (CMPs) being assessed against the department, too.

That could amount to huge dollars, depending on the size and the scope of your EMS department’s reach in the community!

The List…
Remember, “the list” contains those persons who at some point were identified to be involved in some kind of fraudulent or abusive activities against the Medicare or Medicaid system.

These people have a verified history of an infraction of some magnitude which prohibits them from being connected with a healthcare entity that receives reimbursement dollars from the Medicare or Medicaid programs.

The OIG has stated that these persons cannot be connected in any way to a department that receives reimbursement dollars from these programs and applies regardless of whether or not the provider actually was involved with furnishing the services. It includes anyone that is part of your department whether they are directly involved in patient care or not.

Our Recommendations
With this in mind we suggest that your EMS department do the following…
  • Verify all new hires by running their name against the exclusion list BEFORE THEY ARE HIRED!
    • No new hire hits the streets, sits in a chair, picks up a broom or sets foot in the station, officially, until they have been verified to not be on the list
  • Periodically re-check all individuals in your department on a regular basis.
  • If possible, run checks on the people you connect with.
    • At the very least, be sure to include language in your contracts that clearly states that those entities can verify persons you interact with who order and sign-off on transports have been verified to not be on the exclusion list. Remember, it’s your department that is responsible for returning a payment if the facility representative has been excluded- not the facility.
Now it’s up to you!
Only you can set the steps in motion to protect your organization. Don’t delay. Do it today!

Remember, this can extend to all contractors, including your billing office. We can insure that every single team member here at Enhanced Management Services has been checked and re-checked and there are not individuals on the exclusion list.

Can your department’s billing office say the same thing?

If you want to connect with an EMS billing contractor that’s on top of the compliance game, then contact us today. Chuck Humphrey is ready to talk with you today so you can gain peace of mind that you are working with a billing contractor that takes these matters seriously.

You can e-mail him at chumphrey@enhancedms.com or call him toll-free at (800) 369-7544, Extension 108.
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