OIG Model Compliance Plan / Common Fraud and Abuse Concerns / Employee-Contractor Screening

Why This Topic Matters

Organizations can face compliance risk if they hire or retain individuals or contractors who are ineligible to participate in federal health care programs. The article helps readers understand the broader screening and monitoring practices that support a compliance program.

Article Sections

1. Screening policies for employees and contractors

   Overview of compliance-plan expectations for vetting people before hire and during ongoing business relationships. The section addresses general background screening and exclusion-related review processes.

2. Background investigation sources and checks

   Discussion of general sources used to verify licensing, certification, criminal history, and participation status. It also references government databases and reporting resources relevant to screening.

3. Ongoing monitoring and reporting responsibilities

   Explains periodic review of existing workers and contractors and the expectation that certain changes in status be reported internally. The section also covers broader compliance-program monitoring responsibilities.

4. Handling pending or adverse status determinations

   Addresses how compliance programs should treat individuals when concerns are unresolved or when adverse outcomes occur. The section focuses on supervision, removal from certain duties, and continued relationship restrictions.