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Verification of Emloyees Eligibility to Participate in Federal Health Care Programs Policy


Please see the respective policy below.


SIU School of Medicine

SIU HealthCare








SIU collectively applies to the SIU School of Medicine (SIU SOM), (including the Federally Qualified Health Center (FQHC)), and SIU HealthCare (SIU HC).  It is the policy of the SIU through the Department of Human Resources or as contracted to make reasonable inquiry into the background of prospective and current employees whose job function or activities may materially impact the Medicare/Medicaid claim development and submission process, the organization’s relationship with physicians, or referral patterns between providers.


I. Background


SIU is committed to ensuring billing policies and procedures adhere to all federal and state compliance regulations. Towards this effort, SIU has approved a series of policies to meet this commitment. 


II. Policy


SIU shall not knowingly employ (either as a bona fide employee or as an independent contractor), an individual or entity that is listed by a federal agency as excluded, suspended or otherwise ineligible for participation in federal programs to hold any position or render any services for which the individual’s or entity’s compensation or the services rendered by the individual or entity are paid in whole or in part, directly or indirectly by a federal health care program or otherwise with federal funds.


In order to carry out this policy, the SIU SOM Human Resources and SIU Medical Staff Office makes reasonable inquiry into the status of any potential employee or independent contractor.  Such a reasonable inquiry is made during the hiring process and monthly thereafter.  The process includes:


A.  Employees


The following categories of employees, whether new hires or current shall be screened upon hire and monthly thereafter to determine whether they have been listed by a federal agency as debarred, suspended or otherwise ineligible for federal program participation.


  1. Any person hired into a position assigned to or located in a clinical support unit regardless of type or length of appointment.
  2. Any contractual appointment, (including those without pay) in a clinical unit or clinical support unit.


B.  Inquiry


In attempting to ascertain whether an individual or entity is ineligible, SIU SOM Office of Human

Resources and the SIU Medical Staff Office, or as contracted, shall perform compliance screening as follows:


a.  Compliance screening for SIU’s individuals and vendors against specified government exclusion lists. 

These lists include:


b.  Annual Screening Resolution:  Review and resolve all matches of names against the Government Exclusion Lists.

c.  Annual Screening Reporting:  An Audit Trail report will be maintained of the exclusion status for each record submitted along with a signed Executive Summary.


d.  Monthly Rescreening:  SIU’s data shall be re-screened on a monthly basis.


Any information obtained from the database will be reviewed with both the SIU SOM legal counsel and the Compliance Officer. In addition, all applicable hires will be required to sign the Employee Certification Form, a statement attesting to the fact that they are not now or have ever been debarred, suspended or otherwise ineligible for participation in federal programs.


Additionally, the SIU will remove from responsibility for, or involvement with, the SIU’s federal health care program business operations any employee who becomes suspended or is proposed for exclusion during the individual’s employment with SIU until the resolution of such suspension or proposed exclusion. 


In addition, if any employee of the SIU is charged with a criminal offense relating to its federal health care program business, the SIU will remove that employee immediately from responsibility for, or involvement with, the SIU federal health care program affairs.  If an employee is convicted or debarred, the SIU  shall remove this individual from any position for which the individual’s salary or the services rendered by the individual are paid in whole or in part, directly or indirectly by the federal health care programs or otherwise with federal funds. The SIU shall notify OIG of each such personnel action taken and the reasons therefore, within thirty (30) days of the action.


The SIU shall not knowingly allow, or cause to be allowed, any person convicted in any local, state, or federal court of any felony involving health care matters to hold the position of director, officer, or manager of the SIU, or any of its agents either through an employment agreement or an independent contract.


Adopted:  January 20, 1999

Contact:  Compliance Officer


Approved by OCP: 1/11/2017

Approved by Quality and Safety:  2/21/2017               


Exclusion entities instruction (42 U.S.C. § 1395w-27(g)(1)(G))

Social Security Act §1128 and 42 U.S.C. Section 1320a-7

Social Security Act  §1156 and 42 U.S.C. Section 1320c-5

42 Code of Federal Regulations Section 1001.1901