Sanctions are identified by reviewing the OIG, EPLS, Office of Foreign Assets, National Practitioner Data Bank (NPDB), Michigan Department of Corrections, and Sexual Offender Registry Search.
HHS OFFICE OF INSPECTOR GENERAL (OIG):
The HHS OIG is authorized by The United States government to conduct investigation, audits, and evaluations relating to health care fraud. Health care fraud includes but is not limited to submitting false claims to Medicare or Medicaid programs.
Any individual who is found to have acted improperly in dealing with Medicare or Medicaid will have civil monetary penalties placed upon him/her. In addition, that individual will be restricted from working for any institution that receives federal funding for Medicare or Medicaid. If an institution employs an individual who has in fact been sanctioned by the HHS OIG then that institution will suffer severe penalties from the HHS OIG.
EXCLUDED PARTIES LIST SYSTEM (EPLS)/SYSTEM FOR AWARD MANAGEMENT (SAM):
The Excluded Parties List Systems (EPLS) identifies parties excluded from Federal Procurement and Non-procurement Programs. These parties are excluded throughout the U.S. Government from receiving Federal contracts or certain subcontracts and from certain types of Federal financial and nonfinancial assistance and benefits.
OFFICE OF FOREIGN ASSETS:
Identifies individuals who engage in terrorist activity against the United States. As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for, or on behalf of targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” Their assets are blocked and U.S. persons are generally prohibited from dealing with them.
The NPDB is a federal repository which contains confidential information on health care providers, practitioners, entities and suppliers. Its primary goals are to improve the quality of health care for the public and reduce fraud and abuse.
Federal law requires that the following adverse actions are to be reported to the NPDB:
- Medical malpractice payments
- Adverse state licensure & DEA registration actions
- Adverse clinical privilege actions
- Adverse professional society membership actions
- Exclusions from Medicare, Medicaid and other federal health care programs
- Negative actions or findings by peer review organizations
MICHIGAN DEPARTMENT OF CORRECTIONS:
This is a search of The Offender Tracking Information System (OTIS) containing information about more than 300,000 prisoners, parolees and probationers in Michigan. Incarceration and probation dates are available.
SEXUAL OFFENDER REGISTRY
This is a search of State and National Database registries for convicted sexual offenders.