在授予医生特权时，许多组织将重点关注先前的医疗事故解决方案，以确定个人的潜在责任风险。仅通过医疗事故来判断医生的能力并不是表明表现的最佳方式。甚至监察长办公室 (OIG) 也敦促医疗机构在授予特权之前查看许可历史和不当行为：“国家许可委员会和医疗保健提供者的纪律处分比医疗事故付款更好地表明专业无能。”
医院和卫生组织被授权检查OIG和总务管理局 (GSA)数据库和制裁名单，以确保员工不会被禁止参与联邦计划，如医疗保险或医疗补助。一些雇主可能没有意识到这些联邦系统中不存在州级制裁。即使一家医院符合规定，并且新员工没有出现在联邦名单上的制裁名单中，该人也可能会受到州级制裁，而且很快就会上升到联邦级。如果医院使用联邦批准的员工从 Medicaid 或 Medicare 中报销服务费用，可能会导致罚款，有时还会以企业诚信协议 (CIA) 的形式进行更多监督。CIA 是 OIG 与医疗保健提供者之间的协议，对组织实施严格的合规举措。
Health care organizations, who meet federal and state regulations when it comes to pre-employment screening, may still be at risk for employing excluded individuals. When an organization employs someone who is ineligible, it is at a greater risk of incurring fines, penalties and reputation damage.
Unknowingly hiring someone who is on a federal or state sanction list is one the biggest threats, but there are others. Below we’ll share tips on how to avoid the five hidden gaps in health care pre-employment screening programs.
Hidden Gap #1: In-state only license validation
Health care organizations may not look across state lines for prior problems, like a revoked license. Unfortunately, states are not required to communicate with one another about a candidate’s license history. There may be out-of-state problems hiding in an employee’s past that go unnoticed during background screening. Unknowingly hiring an individual with a questionable license history increases an organization’s liability risk and poses increased risks to patient and employee safety.
Bridge the Gap: To more easily check for licensing problems across state lines, use an electronic health care screening solution. Be sure the solution covers all of the state licensing boards, allowing the software will fill in any gaps in a candidate’s prior history that an in-state only search may not find.
Hidden Gap # 2: Using malpractice alone as a performance indicator for physicians
When it comes to granting privileges to physicians, many organizations will focus on prior malpractice settlements to determine the potential liability risk for the individual. Judging a physician’s competency by malpractice alone is not the best way to indicate performance. Even the Office of Inspector General (OIG) urges health care institutions to look at both licensing history and malpractice before granting privileges: “Disciplinary actions by state licensing boards and health care providers are better indicators of professional incompetence than malpractice payments.”
Bridge the Gap: The more a hospital knows about a candidate’s professional history, the more informed privileging decisions will be. To mitigate the risk of negligent credentialing liability, don’t stop with malpractice. Use an electronic screening database that reveals a physician’s entire national licensing history to reveal any additional red flags before granting privileges.
Hidden Gap # 3: Invisible sanctions
Hospitals and health organizations are mandated to check against the OIG and General Service Administration (GSA) databases and sanction lists to be sure employees are not barred from participating in federal programs like Medicare or Medicaid. Some employers may not realize that there are state level sanctions which are not present in these federal systems. Even if a hospital meets the regulations, and the new hire does not show up as sanctioned on the federal lists, the individual might be carrying state level sanctions that will soon rise to the federal level. If the hospital bills for services to be reimbursed from Medicaid or Medicare using federally sanctioned employees, it can result in fines and sometimes more oversight in the form of a Corporate Integrity Agreement (CIA). CIAs are agreements between the OIG and a health care provider that impose rigorous compliance initiatives on an organization. These agreements can last up to five years and are meant to ensure the organization is compliant and able to participate in federal programs in the future.
Bridge the Gap: Organizations that go above and beyond the mandated screening requirements will be better protected against employing sanctioned individuals. The best way to check for hidden sanctions is to use a national electronic screening database that covers a candidate’s state and federal sanction history.
Hidden Gap # 4: Poor employment history analysis
Not many companies do a deep enough analysis and verification of prior employment history. Due to the investment in post-graduate education and the specialized training received, health care workers rarely leave the industry. Therefore, any gap in a health care professional’s resume deserves careful consideration. Many times there are licensing and integrity issues hiding in those gaps.
Bridge the Gap: If a candidate has a gap in their employment, ask the candidate to explain the gap. Ask whether they were working outside of the health care industry and why. Verify the information the individual provides through a comprehensive health care screening database and by contacting previous employers.
Another big area for red flags is a change in state residency that coincides with an employment gap, because the individual may have crossed state lines in order to hide a prior offense or license issue.
Hidden Gap #5: Minimal abuse and criminal checks
Sex offenders tend to move from state to state to hide their histories. An out-of-state offense can remain undetected on a hospital’s local registry. If an organization only checks its own state for sexual abuse, it is putting the hospital’s employees and especially patients at risk.
Many background checks only check for in-state criminal activity and reach back as little as seven years. Minimal searches leave huge areas of information uncovered that can indicate fraud, abuse and other integrity issues that make a candidate high risk.
Bridge the Gap: With very little time and investment, a company can layer national searches on top of their state level searches for abuse, fraud and other offenses. Broadening the scope of the search and casting a wider net can fill in gaps of information not covered by state-wide searches alone.
When it comes to pre-screening health care employees, it’s not enough to simply follow minimum state and federal regulations. Cover all of the hidden gaps with a more extensive pre-employment screening program. It will often better protect your health care organization in the long run.。