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Exclusions Checking

UConn Health conducts exclusion checks on its employees, contractors, vendors, students, residents, fellows and volunteers to ensure compliance with Federal law.

Federal law prohibits excluded persons from furnishing items or services that are payable by Federal health care programs. Healthcare providers like UConn Health that participate in Federal healthcare programs are prohibited from employing or contracting with excluded persons to provide items or services that are payable by a Federal health care program. Organizations and individuals that violate these provisions may be subject to civil money penalties and/or civil or criminal prosecution.

Exclusion checks also ensure that UConn Health does not engage individuals:

  • Whom the U.S. government has suspended or debarred from Federal programs, or
  • Whom a state has excluded from a government program in the state, when UConn Health participates in that state program (for example, a neighboring state’s Medicaid program).

Frequently Asked Questions

Q1. What is exclusion checking?

A1. “Exclusion checking” is UConn Health’s process of verifying that a current or potential employee, contractor, vendor, student, resident, fellow or volunteer is not classified as excluded, suspended or debarred by any Federal agency and certain state agencies.

Q2. What does it mean to be excluded, suspended or debarred?

A2. Exclusion - An excluded person is someone listed on the Office of Inspector General (OIG) List of Excluded Individuals and Entities. This list identifies individuals whom the OIG has excluded from participating in Federal healthcare programs like Medicare and Medicaid. The OIG excludes individuals from participating in Federal healthcare programs for a number of reasons, including (but not limited to) criminal convictions related to fraud, patient abuse/neglect or controlled substances.

Many states maintain similar lists that identify individuals whom the state has excluded (i.e., prohibited) from participating in government-funded programs in the state.

Suspension and Debarment - A suspended or debarred person is someone listed on the General Services Administration’s System for Award Management (SAM) Exclusions List. The SAM list identifies individuals who are ineligible to participate in Federal programs or contracts, typically because of fraud, tax evasion or similar improprieties.

Q3. Why does UConn Health conduct exclusion checks?

A3. UConn Health conducts exclusion checks on its employees, contractors, vendors, students, residents, fellows, and volunteers to ensure compliance with Federal law.

Federal law prohibits excluded persons from furnishing items or services that are payable by Federal healthcare programs. Healthcare providers like UConn Health that participate in Federal healthcare programs are prohibited from employing or contracting with excluded persons to provide items or services that are payable by a Federal healthcare program. Organizations and individuals that violate these provisions may be subject to civil money penalties and/or civil or criminal prosecution.

Exclusion checks also ensure that UConn Health does not engage individuals:

  • Whom the U.S. government has suspended or debarred from Federal programs, or
  • Whom a state has excluded from a government program in the state, when UConn Health participates in that state program (for example, a neighboring state’s Medicaid program).

Q4. My role at UConn Health is not related to patient care or any other item or service that is separately payable by a Federal health care program. Why am I subject to an exclusion check?

A4. The prohibition against employing or contracting with excluded persons extends beyond direct patient care and applies regardless of whether the items or services furnished by the person are separately billable to a Federal healthcare program.

For example, excluded persons may not perform administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to Federal healthcare programs. In addition, excluded persons may not serve in executive or leadership roles at a healthcare organization that furnishes items or services that are payable by Federal health care programs.

It is often difficult to determine whether an individual’s role is or is not wholly unrelated to Federal healthcare programs. For that reason, UConn Health conducts exclusion checks on a wide variety of employees, contractors, vendors, students, residents, fellows, and volunteers.

Q5. How does UConn Health conduct exclusion checks?

A5. UConn Health uses a third party vendor to conduct exclusion checks on its behalf. The vendor checks the OIG and SAM lists and other relevant Federal and state lists for the name of the employee (or contractor, vendor, student, resident, fellow, or volunteer, as applicable) to ensure that they are not excluded, debarred or suspended.

Q6. Why is UConn Health asking me for more information, such as my date of birth or middle initial, in connection with exclusion screening?

A6. UConn Health will ask you for more information if the exclusion check shows that someone with the same name as you is on the OIG or SAM list or is otherwise excluded or debarred from a relevant Federal or state program. This additional information is needed to confirm whether or not you are the person listed. We ask for the minimum amount of information necessary to make this determination, which in most cases is date of birth, middle initial or middle name, and/or previous residences.

Q7. What if I do not want to provide additional information to UConn Health?

A7. If you are not comfortable providing the additional information needed to confirm that you are not excluded, suspended or debarred, you may submit a signed affidavit to UConn Health confirming that you are not excluded, suspended or debarred.

Q8. Who can I contact with additional questions?

A7. If you have additional questions that have not been addressed here, please contact Bridget Richard from the Office of Healthcare Compliance and Privacy. She can be reached at 860-679-4177 or brichard@uchc.edu.