DATE: September 2010 - Sanctioned Excluded Provider Verification Service
What — Healthcare entities are required to ensure that their employees and vendors are not sanctioned by Federal or State regulatory
provider is an individual or business that has violated one more regulations and has been penalized through statutory or regulatory
process from participation in a governmental program, such as Medicare or Medicaid.
How — The various regulatory agencies involved include OIG (US Department of Health & Human Services Office of Inspector
General), GSA (US General Services Administration), NYS OMIG (New York State Office of the Medicaid Inspector General), and many
more. These agencies each keep lists of excluded individuals and the lists are available for healthcare entities to utilize for name
comparison purposes. The verification process entails two steps outlined below.
Commercial Investigations LLC outsources the first step of the process through a valued partnership with The Taiga Group LLC, a
healthcare consulting firm based in Albany NY that specialized in Corporate Compliance. The Taiga Group developed an easy to use
and fully HIPAA secure process called TaigaCheckTM that will perform the first step—checking of all your employees, medical staff and
vendors every month at very reasonable rates. This process identifies potential matches via name, provider number (UPIN) and tax
identification number. While this step is effective in identifying potential exclusions, there exists another level of identification and
verification necessary for confirmation.
The TaigaCheck™ comparison is the first step in identifying potentially damaging sanctioned, excluded or disbarred entities. The
second step involves making positive or negative identification of name matches to the employees or vendors. The investigators at
Commercial Investigations LLC provide hands on manual research to make positive identifications of excluded individuals. This step is
typically not available from the data matching providers and thus left up to the healthcare entity staff. Commercial Investigations LLC
provides cost effective research by seasoned investigators that allow healthcare entities to outsource this process, saving staff time
and shifting any associated liability.
This second step is a manual process and Commercial Investigations LLC investigators are well versed in making the necessary
identifications. The experienced investigators at Commercial investigations LLC conduct the second step involving the positive or
negative identification. The end result is a list of individuals that have been positively identified as being excluded by one or more
regulatory agencies through more than one personal identifier match (i.e. name and Social Security Number or Provider Number or
Data of Birth or Address or Federal Tax Identification Number, etc.).
Why — The regulatory agencies databases released for the verification process do not contain sufficient personal identifiers to make a
positive identification. So, these databases are used to make name matches, usually only first and last name. Because many people
have the same name the second step is necessary for positive identification. The first step is usually offered by either compliance
companies, data provider companies or computer software information technology companies. However, most of them do not offer
assistance with making the positive identification necessary after the name matches are revealed. This is where the trained and
experienced investigators of Commercial Investigations LLC come in with their expertise.
Who — Commercial Investigations LLC, a woman-owned licensed private investigative agency, offers thorough and affordable
employment Background Investigations. CI provides accurate, timely, cost effective and fully compliant reports supported by high
standards of customer service. CI also offers consulting services to assist organizations with reviewing and auditing their Background
Investigations processes for compliance, effectiveness and efficiency. CI provides the Proactive Truth™ regarding applicants, thereby
reducing turnover and limiting exposure to civil liability.
Commercial Investigations LLC assists employers with protecting their employees, customers and overall businesses through their
Background Investigations and Consulting Services. For more information visit our website at www.commercialinvestigationsllc.com or
call us at 800-284-0906.