Regional News : Pennsylvania HealthChoices
New Requirement for Medicaid Providers: Screen and Report Any Excluded Employees or Contractors
The Pennsylvania Office of Mental Health and Substance Abuse Services (OMHSAS) recently released Medicaid Bulletin # 99-11-05, which requires all Medicaid providers to regularly screen prospective employees and contractors to see if they have been formally excluded from participation in federal health care programs. Providers are required to immediately report any such instance of exclusion to the Pennsylvania Bureau of Program Integrity.
The State recommends that providers establish a set of policies and procedures for regular screening of exclusion lists for employees and contractors. The intent of the requirement is to make sure that providers do not include in any part of service delivery or reimbursement an individual who is no longer permitted by law to participate in the Medical Assistance (MA) Program.
The State now requires that providers regularly check the following three lists for excluded individuals or entities:
- The Pennsylvania Medicheck List: a database maintained by the State that identifies providers, individuals, and other entities that are precluded from participation in Pennsylvania's MA Program;
- The List of Excluded Individuals/Entities (LEIE): a database maintained by the U.S. Department of Health and Human Services' Office of Inspector General (HHS-OIG) that identifies individuals or entities that have been excluded nationwide from participation in any federal health care program; and
- The Excluded Parties List System (EPLS): a worldwide database maintained by the U.S. General Services Administration (GSA) that provides information about parties excluded by various federal agencies.
In terms of the frequency of checking these lists, the State requires providers to:
- Check all three lists prior to hiring an employee or contractor;
- Check all three lists monthly for every employee (i.e., newly hired and current employees/contractors); and
- Check all three lists whenever another of the lists is checked because one might contain information that the others do not.
If an employee or contractor is found to be excluded, providers should immediately notify Pennsylvania BPI through one of the following routes:
- Online via the MA Provider Compliance Hotline Response Form.
- By mail at the Bureau of Program Integrity, Commonwealth of Pennsylvania, P.O. Box 2675, Harrisburg, PA 17105-2675.
- By fax at 1-717-772-4655 or 1-717-772-4638.
The State also recommends that providers maintain auditable documentation of exclusion screening efforts, including dates the screenings were performed, the source data checked, and the date of its most recent update. Finally, providers should periodically conduct self-audits to determine their own compliance with this requirement.
For more information, please visit www.MagellanofPA.com.