The Centers for Medicare & Medicaid Services (CMS) updated Medicare Care Compare to include doctor and clinician facility affiliation information for the following facility types, as applicable (noting this is in addition to the hospital affiliations previously available):
- Long-term Care Hospitals (LTCHs)
- Skilled Nursing Facilities (SNFs)
- Inpatient Rehabilitation Facility (IRFs)
- Home Health Agencies
- Hospices
- Dialysis Facilities
This update is especially helpful to patients and caregivers since it:
- Provides additional information to support patients and caregivers as they make healthcare decisions.
- Offers information about clinicians who aren’t affiliated with a hospital but work in other types of healthcare facilities.
- Creates additional quality information linkages between clinicians and facilities across Care Compare pages.
Visit the profile pages in the Doctors and Clinicians section on Care Compare to view the update at the link provided above. The facility affiliations are displayed in a dedicated “Affiliations” section for easy access. Group affiliations will continue to be listed separately in the “Details” section as a fundamental part of a clinician’s profile.
Compliance Perspective
Issue
Facilities are responsible for ensuring that they do not employ or contract with excluded individuals or entities, whether in a physician practice, a clinic, or in any capacity or setting in which federal and state healthcare programs may reimburse for the items or services furnished by those employees or contractors. This responsibility requires screening all current and prospective employees and contractors against OIG’s List of Excluded Individuals and Entities (LEIE) at https://exclusions.oig.hhs.gov. Anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties (CMP). To avoid CMP liability, healthcare entities should routinely check the lists to ensure that new hires, current employees, and other agents of the facility are not on it.
Discussion Points
- Review your policies and procedures for screening of potential employees to confirm that they are not included on a state or OIG exclusion list. In addition, review your policies and procedures for frequency of checking the OIG Exclusion List for all current employees and vendors. Update policies as necessary.
- Train all appropriate staff on the requirement for checking the OIG LEIE link for all new potential hires, current employees, vendors, and other agents, and the frequency for repeating the checks. Document that the trainings occurred and file the signed document in each employee’s education file.
- Periodically audit to ensure that all new employees have been confirmed as not being on the OIG LEIE. Also, determine that routine checks are being conducted for current employees to ensure that they have not been added to the OIG Exclusion List after a previous check was completed. Ensure that a copy of the OIG LEIE screening confirmation is included in each employee, vendor, or other facility agent file.
*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*
