PIEDMONT ACCESS TO HEALTH SERVICES, INC.

Policy Number:01-14-014

SUBJECT:Exclusion Screening

EFFECTIVE DATE:08/21/2012

REVIEW/REVISED:10/16/2013, 09/10/2014, 06/14/2016

PURPOSE:

It is the policy of PATHS to comply with Federal and State mandates to screen employees, independent contractors, and board members to verify that they have not been involved in adverse governmental actions related to fraud, patient abuse, licensing board sanctions, license revocation/suspension/surrender, or have defaulted on Health Education Assistance Loans. PATHS is committed to maintaining high quality service and integrity in its financial and business operations, therefore, all necessary steps will be taken to insure that healthcare-related employees, providers, contractors, etc., that provide and/or perform services for or on behalf of PATHS have not been the subject of adverse governmental actions and/or excluded from the federal healthcare programs.

POLICY:

PATHS will perform initial, annual and/or ongoing exclusion reviews to ensure that employees, contractors and volunteers and Board members have not been sanctioned or excluded from participating in any federal health care program as prohibited by federal law.

For purposes of this policy, an “ineligible individual/entity” is anyone who:

  1. Is currently excluded, debarred, or otherwise ineligible to participate in the federal health care programs or in federal procurement or non-federal procurement programs; or
  1. Has been convicted of a criminal offense related to the provision of health care items or services but has not yet been excluded, debarred, or otherwise declared ineligible.

PROCEDURE:

The following screening procedures will be conducted by PATHS’ Human Resources Department.

  1. Human Resources Screening.
  1. Screening Prior to Hire.

Prior to the hiring of any PATHS employee, the Human Resources Department will screen all potential employees by reviewing the United States General Services Administration List ofParties Excluded from Federal Programs (“GSA Exclusion List”) and the United States Department of Health and Human Services Office of Inspector General List of Excluded Individuals/Entities (“OIG Exclusion List”).

The Human Resources Department shall notify the Chief Executive Officer and the Compliance Officer of any matches found during the above screening processes. If a potential employee is determined to be an Excluded Individual, the individual will no longer be eligible for hire.

B. At hire

At hire, all employees are required to sign the “Standards of Conduct Policy” (Policy # 02-04-017) which is given to them along with the new employee paperwork certify that the employee has not been excluded, has no knowledge of an impending exclusion, and agreement to notify the Compliance Officer if they should become aware of their potential exclusion.

C. Annual Screening.

Upon the effective date of this policy, and annually thereafter, PATHS will screen all current employees to verify that all existing employees have not been excluded from federal programs since the last review. If identified that a current employee is an ineligible individual/entity in the Exclusions verification process, PATHS’ Chief Human Resources Officer, Chief Executive Officer and Compliance Officer will meet to decide on the appropriate course of action.

2. Credentials Verification.

A. Initial Application Screening.

CCNV is responsible for exclusion screening when credentialing PATHS’ Providers. CCNV shall query the OIG Exclusion List as part of its primary source verification process for each application for credentialing in accordance with their policies and procedures. Potential PATHS’ Providers will be required to, as part of the credentialing process, attest that they have not been excluded from a federal health care program. CCNV shall notify the Chief Human Resources Officer of any matches found during any of the above screening processes.

B. Bi-Annual Screening.

CCNV is responsible for exclusion screening when recredentialing PATHS’ Providers. CCNV shall query the OIG Exclusion List as part of its primary source verification process for each application for recredentialing in accordance with their policies and procedures. PATHS’ Providers will be required to, as part of the recredentialing process, attest that they have not been excluded from a federal health care program. CCNV shall notify the Chief Human Resources Officer of any matches found during any of the above screening processes.

3. Compliance Officer

The PATHS’ Compliance Officer shall request annual reports from the Human Resources Department regarding their screening activities, as needed.

SIGNATURES:

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Chief Executive OfficerDate

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Chief Operating/Compliance OfficerDate

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Chief Human Resources OfficerDate

01-14-014 Exclusion Screening

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