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

City of West Palm Beach
basis.
(c) If an employee is an Ineligible Person on either list, the VP, Employee
Relations will notify the HR Director at the facility which employs the
Ineligible Person.
(d) The HR Director must terminate the employment relationship with that
individual.
(e) The VP, Employee Relations will report the match and the action taken by the
facility to the VP, Reimbursement and Director, Internal Compliance
Reporting
ii. Facility-Based Screening.
(a) Facilities located in states which maintain a state exclusion list must search the
state exclusion list on a monthly basis to ensure that no employee is an ineligible
person.
(b) If an employee is an Ineligible Person on the state list, the HR Director must
terminate the employment relationship with that individual.
(c) A list of states with exclusion lists is available on Atlas.
c. Each employee must immediately disclose to his or her supervisor any debarment,
exclusion or other event that makes the employee an Ineligible Person. The supervisor
must report such disclosures to the HR Director, and the HR Director must terminate the
employment relationship with that individual.
d. The HR Director must notify the facility’s Division Reimbursement Manager to address
potential cost reporting issues and report the disclosure or match and subsequent actions,
including the final disposition, to the facility Ethics and Compliance Officer (ECO).
e. If the ineligible person is a Corporate payroll employee, the VP, Employee Relations, will
work with the Corporate Reimbursement department to address cost reporting issues, and
report the match or disclosure and subsequent actions, including the final disposition, to
the Director, Internal Compliance Reporting.
f. Documentation:
i. Whenever a search of the GSA List, the OIG Sanction Report, or applicable state
exclusion list is conducted by the background investigation vendor or a facility
undertakes to confirm a possible match, the search results must be documented and
copies of the search information should be maintained in an electronic file,
separate file or in a master exclusion verification file filed by year and
alphabetized for applicants not employed.
ii. Documentation required for searches performed on SanctionCheck.com:
a) Documentation required when batch file results from SanctionCheck.com indicate a possible
OIG or GSA List match:
� A Batch Summary Report must be printed.
� An individual certificate summary must be printed for all “Positive Matches Only” (both
OIG and GSA positive matches).
b) Documentation required regardless of SanctionCheck.com search results:
� The “All Names Submitted” file must be downloaded when the Batch Results page
displays.
� The list used to develop a batch search must be printed and saved.
iii. Electronic storage is also an acceptable storage option provided the documents are
readily available on demand. A procedure for backing up documents in the event
of system malfunction should be established to ensure accessibility.
iv. All records regarding ineligible persons search results must be maintained
All rights reserved. This document contains proprietary and confidential information which may not be reproduced or shared without the written consent of First Onsite. 4