New Sanction Screening Challenges for Managed Care Organizations

Pursuant to the U.S. Department of Health and Human Services (HHS) Office of Inspector General’s (OIG’s) “Compliance Program Guidance for Medicare + Choice Organizations Offering Coordinated Care Plans,” managed care organizations (MCOs) are mandated to screen all employees and contracts, which include physicians within their network.  The guidance states that they should “utilize Government resources to determine whether such individuals or entities are debarred or excluded.” Furthermore,”[l]ists of debarred and excluded individuals and entities are currently maintained by both the OIG and the General Services Administration.”

About the Author

Jillian Concepcion is a highly experienced compliance consultant, having provided advisory services to clients in the development, evaluation, and improvement of their compliance and privacy programs. Ms. Concepcion specializes in working with health care organizations to implement CIA requirements, including development of the CIA implementation report, general and specific compliance training, policies and procedures and sanction screening process.