Agenda Cover Memorandum for 02/ - City of West Palm Beach

City of West Palm Beach
individuals that is processed against the OIG Sanction Report and the GSA List at the same time.
Instructions for individual and batch search using SanctionCheck.com are on the website at
http://app.sanctioncheck.com.
PROCEDURE:
1. Hiring of Former Fiscal Intermediary(FI)/Medicare Administrative Contractor (MAC)
Personnel
a. In the event a facility hires a former FI/MAC employee, the Human Resources Director
will prepare a letter similar to the attached example and forward it to the Department of
Health and Human Services.
b. The Human Resources Director will retain a copy of the letter to be available during a
survey or certification visit. A copy will also be placed in the employee’s personnel file.
2. Prohibition Against Employment of Ineligible Persons
a. Screening Prior to Employment.
i. Prior to hiring or re-hiring an employee, the Human Resources Director or designee
must ensure that the individual being considered for employment has been checked
against the:
(a) General Service Administration’s List of Parties Excluded from Federal Programs
(the “GSA List”);
(b) HHS/OIG List of Excluded Individuals/Entities (the “OIG Sanction Report”); and
(c) Any applicable state exclusion list.
ii. The Human Resources Director or designee or the vendor providing background
investigations will compare the name and address of each potential candidate for
employment to the GSA List and the OIG Sanction Report. Should an individual
appear on either the GSA List or the OIG Sanction Report, the Company may not
employ that individual.
iii. The GSA List and the OIG Sanction Report are on the Internet in searchable formats at,
respectively:
� http://epls.arnet.gov ; and
� http://exclusions.oig.hhs.gov.
� Alternatively, both lists may be searched simultaneously at:
http://app.sanctioncheck.com. This is the recommended method of conducting
ineligible persons searches.
b. Screening Subsequent to Employment.
i. Corporate Office-Based Screening.
(a) On a monthly basis, Corporate Information Technology & Services (IT&S)
will compare the Company’s employee database against the GSA List and the
OIG Sanction Report and provide the report of the comparison, which lists
potential matches, to the Corporate Human Resources’ VP, Employee
Relations.
(b) The VP, Employee Relations is responsible for confirming the match by
reviewing the GSA list on a semi-annual basis and the OIG list on a monthly
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