How often to check, and why monthly
What the rules say about screening frequency, why most organizations check monthly, and what continuous monitoring should mean in a tool.
What the rules say
OIG’s 2013 bulletin advises checking the LEIE before working with someone and periodically afterwards, and notes that the LEIE is updated monthly. State Medicaid agencies must check their enrolled providers against the LEIE and SAM.gov at least monthly, and Medicare Advantage plans must check their contractors monthly.
Many state Medicaid provider agreements and managed care contracts set their own interval. Your contracts decide; monthly is the common floor.
Once at the start is not enough
A person can be added to a list at any time after you start working with them. A check at onboarding alone leaves every later month unchecked, and payments for those months are what create repayment exposure.
What monitoring should mean in a tool
Look for a tool that re-screens your whole roster on a schedule you set, against every list, without someone starting each search. It should tell you only when something needs a person to look at it.
- Is our whole roster re-screened automatically each month, or only new records?
- Can we choose the screening day to fit our compliance calendar?
- How are we told about a new potential match between scheduled runs?
Read more
Sources: HHS-OIG: Special Advisory Bulletin on the Effect of Exclusion (2013); 42 CFR 455.436: Federal database checksSee it on your own list
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