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Recent Publications

Health Care Compliance

Over the last 20 years there has been a very strong trend to outsource functions that are not part of the core business of the organization. This certainly has reached the health care sector. The continued increases in the duties and obligations of compliance officers have led many to outsource some of their routine operations.

The trend to do this began with employee hotline services; currently, most organizations use vendors for this function.  Vendors are often used to provide compliance education training programs, many also turn to vendors for compliance-related policy development. Without question, however, the fastest growing outsourcing activity for compliance officers is using a sanction screening software vendor to reduce the increasing burden of exclusion screening. [1]


During my term as U.S. Department of Health and Human Services (HHS) Inspector General, I caused to be created what is now referred to as the List of Excluded Individuals and Entities (LEIE), which was followed by various Office of Inspector General (OIG) compliance guidance documents that call for screening employees, physicians, vendors, and contractors against the LEIE.  [2] Subsequently, the OIG encouraged screening against
the General Service Administration’s (GSA’s) Excluded Parties List System (EPLS), which is now part of the System for Award Management (SAM).

Further complicating matters has been the addition of other federal sanction databases maintained by the Drug Enforcement Administration and Food and Drug Administration. There are also those that feel the need to screen against the terrorist watch list, formally referred to as the Specially Designated Nationals List maintained by the Department of the Treasury Office of Foreign Assets Control.

[1] For examples of all these services, see

[2]OIG “Special Advisory Bulletin on the Effects of Exclusion from Participation in Federal Health Care Programs.” Advisory Bulletin. (May 9, 2013),

Editors Note: This article was published in the March/April 2014 edition of the Journal of Health Care Compliance.

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