exclusioncheck2 ( ec2) chspsc user guide...exclusioncheck2 ( ec2) chspsc user guide. chspsc...

January 2018

ExclusionCheck2 ( EC2)CHSPSC User Guide

CHSPSC Corporate Federal Exclusion Team

[email protected]

Tracey Lowndes, Sr. Director, ComplianceRobin Boyles, Manager, Compliance

Jill Cook, Compliance Support Coordinator

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Table of Contents

Exclusion Check Agencies: 4ExclusionCheck Information: 5ExclusionCheck Access and Log-In Information: 6 – 9 Single Searches (Name/Company/Vendor/Contractor/NPI#): 11 – 19Batch Search By Name: 19 - 31Batch Search By NPI #: 32 – 43Positive Match Instructions: 44Reports: 45OIG Search Guidelines: 46 – 48SAM Search Guidelines: 49 – 55OIG Exclusion Definitions: 56 – 57SAM Exclusions Terminology: 58 – 61Exclusion Agency Points of Contact: 62Glossary of Terms: 63CHSPSC Contacts: 64CHSPSC Attestation: 65CHSPSC Vendor Attestation: 66

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EXCLUSIONCHECK CHECKS ALL OF THE BELOW AGENCIES/SITES:

OIG-LEIE – Office of Inspector General – List of Excluded Individuals and EntitiesGSA-EPLS – General Services Administration – Excluded Parties List SystemSAM – System for Award ManagementOFAC/SDN – Office of Foreign Assets Control/Specially Designated NationalsState Medicaid Exclusion Lists:

Alabama Kentucky North CarolinaAlaska Louisiana North DakotaArizona Maine OhioArkansas Maryland PennsylvaniaCalifornia Massachusetts South CarolinaConnecticut Michigan TennesseeFlorida Minnesota TexasGeorgia Mississippi VermontHawaii Missouri WashingtonIdaho Montana Washington DCIndiana Nebraska West VirginiaIllinois Nevada WyomingIowa New JerseyKansas New York

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ExclusionCheck InformationCommunity Health Systems (CHSPSC) does not employ, retain, or otherwise do business with any Ineligible (sanctioned) Person; this standard applies to all employees, contractors, medical staff members and vendors. Therefore, sanction checks are required to be performed on all employees, contractors, medical staff members and vendors. It is mandatory that ExclusionCheck be used for all sanction screening. PLEASE REFER TO THE CORPORATE COMPLIANCE POLICY ENTITLED “Screening Requirements – Ineligible Person Policy” which can be found in My Policies.• An Ineligible (sanctioned) person is any individual or entity who:

• Is currently excluded, suspended, debarred or otherwise ineligible to participate in Medicare, Medicaid or any other federal or state health care programs.

• Has been convicted of a criminal offense related to the provision of health care items or services and has not been reinstated in the federal health care programs after a period of exclusion, suspension, debarment, or ineligibility.

• Anyone who requires a current professional license by a state, and whose license is expired, suspended, revoked, lapsed, etc., is not eligible for hire, contract, or privileging.

• Additional Information:• Any healthcare organization that bills Medicare/Medicaid cannot employ an excluded/sanctioned

individual or do business with an excluded/sanctioned entity.• By employing an excluded individual or contracting with an excluded party, your organization is at

risk.• Fines for knowingly or unknowingly employing an excluded individual could cost up to $10,000 per

incident (payment of services) per day, plus additional damages.• The best possible solution is to know before you hire and to check all of your employees, contractors,

medical staff members and vendors upon hire and on a monthly basis through ExclusionCheck.

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EXCLUSIONCHECK ACCESS

If your job title/job code is listed on page 7 you should have automatically been provisioned with an ExclusionCheck account.

To access your ExclusionCheck account:Go to chs.exclusioncheck.comEnter your user name-You will use your CHS Network ID (same as the one you use

each morning when logging in). Enter the password you use each morning when logging inSelect Log In

** If you are in a CHS 14 facility, you will use your Advanced Learning CHS Network ID. If you do not know your ALC sign-on, please contact your local HELP Desk. Your password will be the uppercase letter of your first name + lower case letter of your last name + last six digits of your SSN – Example: Cb456789

If you have not been automatically provisioned with an ExclusionCheck account, please follow the Exception instructions listed on page 8 to request ExclusionCheck access.

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The following list of job roles will automatically be provisioned through IDM with Exclusion Check:

Admin. Asst. I –18001 Manager Med Staff Credentials -610108Admin. Asst. II –650540 Medical Staff Coordinator -144201Admin –Sup Cancer Registry –699153 Medical Staff Credentialing Clerk -144101Admin Exec Secretary –17001 Patient Registration LDU -699035Admitting Clerk –87201 Polysom Tech Registered U -699071Admitting Registrar –19001 Pre-Registration Rep -650532Admissions Supervisor –603002 Receptionist -113001Clerk Generalist –650028 Recruiting Specialist -650276Contract Representative –650520 Registrar Cancer Cert -600912Compliance System Asst. –801901 Registrar EDU -900002Director, Admissions –90901 Registrar –ER -650534Director, Business Office –600042 Registrar Lead -603000Director Med Staff Credentials -606862 Registrar Lead U -699198Executive Assistant -604002 Registrar –Outpatient -650536Financial Counselor -27101 Registrar U -699188HR Generalist –68201 / 600177 Registration Coordinator -87101HR Personnel Director -602710 Scheduling Clerk -117001HR Representative -602712 Sr. Director Corp Compliance -801922HR Specialist –602714 VP, Human Resources -650556Insurance Verify Rep -26301Manager of Admissions –603006Manager HR -650555

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EXCEPTION PROCESS FOR OBTAINING ACCESS TO EXCLUSIONCHECK

Login to the CHS networkEnter https://myidentity.chs.net into the URLWait for the Login screen to appearType your username and password in the boxesClick LoginFrom the menu bar make certain you are in Work Dashboard, to the left click “Make a Process Request”Leave “all” in the Process Request CategoryClick “continue”Click on the line “ProviderTrust RBE” and another window will open for you to complete.

Specify a Domain: Use the drop down box and select your facilityExpiration Date: This date has been “hard coded” therefore, skip this entryException Description: Enter “ Access needed to perform sanction screening”Compensation Controls: Enter “Used to monitor sanction screening”Contingency Assessment: Enter “Would be unable to perform sanction screening”

Click the “Submit” buttonThis request will go to your Manager and once the Manager approves , it will then be automatically routed to the facility CFO for approval.You will receive a total of two emails – one from “myidentity”, when you submit the exception process, and another from “ProviderTrust/ExclusionCheck” , once the CFO approves the request.It is important that you wait to receive the email from ProviderTrust/ExclusionCheck before logging into ExclusionCheck or, you will not be in the CHS specific screens.

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ExclusionCheck Log In Screen

Enter your User name and Password - Use information on previous pages regarding access.Select Login.

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The Support Tab is available throughout the system. Clicking on the Support Tab will allow you to directly email an ExclusionCheck support representative.

A Print button is available on all screens.

The Help button will take you directly to the CHS Exclusion Guide.

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Single SearchesAs you can see from the sample screen on the previous page, you have three options for performing single searches: (1) By

Last Name and First Name; (2) Company/Vendor/Contractor Name; (3) NPI Number. You cannot search for more than one

type at the same time.

Last Name, First Name Search• Enter in the Last Name and First Name of the individual you would like to search. To ensure that you are entering the

individual’s correct name it is required that the Social Security Card and/or Driver’s License be used. • DO NOT UNDER ANY CIRCUMSTANCES ADD THE MIDDLE NAME OR INITIAL.• ExclusionCheck does not use the SSN for verification purposes. Regardless of whether the SSN is keyed in to the

Unique Identifier field or not, ExclusionCheck only returns potential matches based on the name entered. The

benefit to keying in the SSN is that the SSN will be displayed in a window to the right of the record you are reviewing, which

can at times help in the process of determining if the potential record is or is not a match to the name you searched. Keying in a Unique ID is not required.

• Select “Search”.

• The system is searching for the name you keyed in and any other names which are similar. For example: If you search for

the first name “Robert” you are also going to see possible matches for Bobby, Bob, etc., as these are nicknames for Robert.

If you search for Robert Smith you are also going to see last names which begin with “Smith” such as Smithson, etc.

Company/Vendor/Contractor/ Name Search• When entering company names, use the most basic part of the company name. Leave out words such as “The, Inc., LLC,

Co., etc. For example when entering “The Monument Firm and Company, LLC” you would enter Monument Firm.

• For companies, the system is searching for the name you enter and also any similar names: Example: When you search for

“Smith Monuments” you will also see possibles for Smith Monuments and Gifts, Smith-Jones Monuments, etc.

• If you have the EIN/TAXID number you can enter (with no dashes) into the Unique Identifier field. It is NOT a requirement to

enter this number. ExclusionCheck does not use the EIN/Tax ID for verification purposes. ExclusionCheck ONLY returns potential matches based on the company name entered.

NPI Search• If this single search is for a provider, you can use the provider’s 10-digit NPI number to perform the search. You will NOT

need to enter the last name, first name. You will only need to enter the NPI number.

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VIEWING RETURNED RECORDS IF SEARCHING BY LAST NAME AND FIRST NAME

Richard was entered as the First Name. Thomas was entered as the Last Name.The Unique ID was left blank.One Primary result is returned and will need to be researched by selecting the Details button. See following page.

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NEVER ENTER A MIDDLE NAME AND/OR INITIAL.ENSURE YOU ARE USING THE INDIVIDUAL’S SOCIAL SECURITY CARD AND/OR DRIVERS LICENSE WHEN ENTERING THEIR NAME.

This screen tells us that the excluded Richard Thomas is Richard W. Thomas. If your Richard Thomas has a different middle name/initial then you would select the “print” icon and note on the copy your individual’s middle name as proof of clearance and keep a copy for your records. You will then select “Clear,” “Under Review,” “Historical Match” or add a note. Save – and print a copy for your records.

If your Richard Thomas also has a middle initial of “W” you would then need to print and note on your copy that the individuals have the same name. You would then proceed to determine if they are the same person by comparing information. If you are unable to determine if they are the same person, you can have the employee complete an Attestation Form found on page 65. Once the attestation form is completed, you will need to keep a copy for your records.

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Single Search with No ResultsAfter entering the individual’s name and selecting the Search button, if there are NO results, the below screen will appear. For this particular entry, there are no possible matches for Alicia Pearson.• Select the printer button and make a copy for your records.

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Viewing Returned RecordsAfter selecting the “Search” button, if there are NO results, the below screen will appear. • There are no possible matches for Uptown Medical Supply.• Select the print button to print a copy for your records.• If you had received possible matches, you would select “Details” and be provided with additional information. You would

use this information to determine if the possible match could be cleared. If enough information was not given, you would then select the Source and proceed to research.

• If you cannot determine, after reviewing the source information, if this is or is not your vendor, you can complete the Vendor Attestation form and forward to that particular vendor. When returned, please keep a copy for your file.

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NPI SINGLE SEARCH

Enter the 10 digit NPI number and select “Search”.

1234567890

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Once you have entered the 10-digit NPI number and have selected “Search” the below screen will appear . Please note the NPI single search results screen includes the NPI number you searched , the name of the individual you searched and the result. Print a copy of the results for your records. If any status other than CLEARED is listed, further action will need to be taken based on the result received.

Number blocked out for privacy reasons.

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Batch Search By NameExclusionCheck provides a process to perform Batch searches:• Batch searches allow you to create a CSV file, using the short or long form template provided by

ExclusionCheck, of a group of individuals, vendors, or referring physicians you wish to search. CHSPSC request that batch searches be used for groups of twenty (20) or more individuals.

• At the current time, Batch Searches can only be performed by Last Name, First Name or company name. • For the monthly Batch screening of Referring Physicians, please use the short form template provided in

ExclusionCheck. When using the short form for the Referring Physicians, please leave the “company column” blank. These forms can be accessed and downloaded directly from the ExclusionCheck website. Once you log-in and select the option to perform a batch search, you will see both downloadable templates toward the bottom of your screen. Select the template you would like to use, and it will download to your computer. You can then open the template and begin filling it out with the names you would like to search. For vendor/company names use only the most basic part of the vendor/company name. Do not include words such as “The, Inc., LLC, Co., etc.”.

• The completed CSV file is then uploaded in ExclusionCheck and any possible matches are generated.• Corporate utilizes batch searches each month when performing the monthly screening process.• You must complete either one of these forms with your data, and save in CSV file format.• Do not edit the header row of the forms in any way. If these forms are altered, the file will not process.

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Batch Search – Short Form

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Batch Search – Long Form

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How To Perform a Batch UploadOnce you have logged into ExclusionCheck, you will see the below screen. • Select the “Search” tab and then select “Batch Name Search”.

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• Once you have selected “Batch Name Search” the below screen will appear.• Select Submit New Batch• After selecting Submit New Batch the screen on the following page will appear

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• Select Browse and locate the CSV file you created• Once you locate your CSV file, select open• Select Upload Batch

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• Once you have selected “Upload Batch” your file will begin to process• Once your batch has processed you will receive an email letting you know the Batch has completedHOW TO CLEAR BATCH RESULTS• After selecting the underlined number in the “Non-cleared Results” column corresponding with your upload, you will be

taken to the below screen, which will allow you to see the results and take action.• The information in the “Name or Company Name” column is the information you provided regarding your employee.

(see example on next slide)• The information in the other columns (“State, Exclusion Type, Exclusion Date, Source”) is the information provided by

the exclusion source for individuals who are possible matches. (see example on next slide)• To determine if the possible match is our employee or not, each possible match must be worked/researched. • The “Status” column will determine your actions (see example on next slide).

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The “Status” column will determine your actions:• Select “Details” for each possible match.

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If “Non-Cleared (New)” is listed in the “Status” column:• Select “Details” to review the record.• The information contained in the small box on the right “Correlated Data” is the information you provided regarding your

employee.• The information contained in the large “Result Details” box is the information pulled by ExclusionCheck on a possible match.

As you can see, the information provided for this particular individual can be cleared, as the possible match has a middle name beginning with ”M,” and your employee has the middle name “Diane.”

• If this information had not been provided, then you would select the Source (in this case, “Texas”) and continue to research.

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The below record indicates that your employee has a middle name of “Diane,” yet the possible match has a middle initial of “M.” It is very important that maiden/married names also be considered. • Select the “Clear” button to clear the record. • Select the printer icon located at the top right-hand corner of the screen to PRINT a copy

for your records.• If you are unable to clear the individual by the below information, you would then select

the Source (‘’Texas”) and research further.

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After researching the source, if you are still unable to determine that an individual can be cleared:• Have the individual sign an Exclusions Attestation Form, verifying that they have never

been excluded (see example below).• Once this attestation has been signed, keep a copy for the individual’s personnel file.• A printable version of the Exclusions Attestation Form can be found on page 65.

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Once you begin to do several batches and have a large cleared file you have the option of using the SEARCH CRITERIA box. The SEARCH CRITERIA box searches by either first name, last name or a combination of first and last.

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NPI BATCH SEARCHES

From the home page of Exclusion Check, hover over the search button at the top right and click “Batch NPI Search”.

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Once you are on the NPI batch search screen, click “Sample CSV” at the bottom of the page. See sample of NPI batch search on following page.

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When you have downloaded the sample file, enter your NPI numbers in Column A, leaving the header name exactly as is. Save the file in CSV format.

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On the NPI Batch Search page of ExclusionCheck, click “Submit New Batch” .

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Select and upload your file.After you upload your file, the file will begin to process. You will receive an email when the file has completed processing. If the column header has been changed or if your formatting is not recognized, you will see the batch status “Processing Complete with Errors” and will need to correct your file.

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Reading Your Overall Results• After you have submitted your NPI batch file, you will see the following categories. See next page

for explanation.

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Definitions:• Submitted by: Contains your user name• Batch name: A clickable link that allows you to reopen your original file• Processed: The exact date and time the file was uploaded• Batch status: Will inform you of your files status during the processing of the upload• NPIs: Shows the number of NPIs you searched on your file• Cleared: Contains a clickable link to show you the NPI’s that are not associated with an excluded

provider• Excluded and Inactive: Contains a clickable link to show you the NPI’s that are either associated

with an excluded person or inactive• Invalid: Shows any numbers that were submitted that are not NPI numbers• Download: Lets you download the complete list of NPI search results• Resubmit: Lets you re-submit your file to be researched. If resubmitted an additional charge will

be made for the resubmission.

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Viewing Cleared NPI Batch Results• After you have uploaded your NPI # batch, you can click the number in the green box to see all the

results for NPI numbers that are CLEAR and have no issues. Details about these results are listed in the table on the right.

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Viewing Excluded/Inactive Results• Clicking on the number under the red Excluded and Inactive box will show any NPI numbers that

are associated with an exclusion result. Details about these results are listed in the table on the right.

• All results located in the red Excluded box must be researched by clicking on the NPI number for additional information.

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Viewing Details on an NPI Number:

• Clicking the NPI number underlined on the left of the table when viewing red or green results will pull up all identification details associated with that NPI.

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What is an Invalid NPI?

• An invalid NPI number means that the NPI number you searched does not exist. You can click the number in the “Invalid” column on your NPI Batch homepage to view which NPI numbers are invalid.

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POSITIVE MATCH INSTRUCTIONS

In the event, after being screened and researched in ExclusionCheck, any

questions arise regarding an individual ‘s status or if the individual is determined to

be sanctioned, or if discrepancies arise between applicant’s disclosed credentials

and the verified information obtained by ExclusionCheck, the Human Resources

Department, Medical Staff Coordinator, or Contract Administrator will notify the

Corporate Compliance department by emailing the

[email protected]. Should any person, physician, medical staff

member, contractor, agent, or vendor be determined as ineligible to participate in a

federally funded healthcare program, that person, physician, medical staff member,

contractor, agent, or vendor will be referred by the Corporate Federal Exclusion

Team to the appropriate Corporate Compliance Director for evaluation, follow-up

and appropriate action.

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BATCH REPORT

ExclusionCheck provides one basic report in the batch search section:Audit Report –This report will generate a spreadsheet , reading the original batch and reporting on the cleared state of each person in thebatch.

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OIG Search GuidelinesTo further research a potential OIG record to determine if it is your employee or vendor, you can either directly select the Source link to the OIG located in the record (recommended) or visit the following website:http://exclusions.oig.hhs.gov/Default.aspx• This will take you directly to the search screen, where you will enter the Last Name and

First Name of the employee you are researching. • If you are researching a vendor selecting the link “Search for a Single Entity,” and enter the

name of the vendor.• After keying in either the Last Name and First Name of the employee, or the Entity Name of

the vendor, select “Search”

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• After selecting “Search,” the below screen will appear.• Any OIG exclusion records matching to the name “Edward Green” will appear in the results

(in this case, there is only one).• Select "Verify" to view the exclusion record in more detail. This will also allow you to key in

the SSN (or EIN if a vendor) to verify if it is a match to your employee (or vendor).

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• After selecting “Verify,” the below screen will appear.• Key in the SSN of your employee (or EIN if vendor), and select the green “Verify” button.• If the entered SSN (or EIN) is NOT a match to the exclusion record, you will see the words “NO MATCH”

displayed in red. If you verify that this is not a match to your employee or vendor, you can clear the record.

• If the entered SSN (or EIN) IS a match to the exclusion record, you will see the word “MATCH” displayed in green. If you verify that this is a match to your employee or vendor, contact the Corporate Federal Exclusion Team immediately.

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SAM Search GuidelinesTo further research a potential SAM record to determine if it is your employee or vendor, you can either directly select the Source link to SAM located in the record (recommended) or visit the following website:www.sam.gov• After going to the link, the below screen will appear. • Select “Search Records” to begin your search.

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After selecting “Search Records,” the below screen will appear.• Enter in the first and last name of the employee you are researching.

Ø Example: Brandon Wells• If you are researching a vendor, enter in the name of the vendor.• After keying in either the full name of the employee or the name of the vendor, select

“Search”.

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After selecting “Search,” the below screen will appear.• You will see a listing of all active SAM records returned for the name “Brandon Wells”.• Select “View Details” to open the record.• There is a Glossary containing definitions of terms and explanations of the different search

criteria for your reference.

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After selecting “View Details,” the below screen will appear.• Scroll down the record until you see “Excluding Agency” • Click the link to view the contact details of the agency.

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Filter your search by using the Advanced Search Option:• Select “Advanced Search – Entity” if you are researching a vendor.

Ø You will then have the option to provide more specific information pertaining to the entity(such as entity type and location).

• Select “Advanced Search – Exclusion” if you are a researching an employee.Ø You will then have the option to provide more detailed criteria for a single search, search

for multiple names, and search using SSN/TIN.

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Advanced Search – Exclusion (for an employee). Search by SSN/TIN by simply keying in the name and SSN of the employee and selecting “Search”.

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• You are able to verify by SSN, but SAM.gov does not often store SSNs in their database. After keying in the name and SSN of your employee, you may get the result "The combination of name and SSN/TIN that you provided did not return any results.”

• This information is good to know, but not necessarily definitive. The result goes on to clarify that either that name is not in SAM, there is no SSN associated with that name, or that the SSN you provided did not match the record.

• It is in your best interest to review ALL name matches to your employee and contact the excluding agencies to get more information.

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Federal Statute Definition

1128Scope of exclusions imposed by the OIG expanded from Medicare and State health care programs to all Federal health care programs, as defined in section 1128B(f)(1).

1128a1 Conviction of program-related crimes. Minimum Period: 5 years1128a2 Conviction relating to patient abuse or neglect. Minimum Period: 5 years1128a3 Felony conviction relating to health care fraud. Minimum Period: 5 years1128a4 Felony conviction relating to controlled substance. Minimum Period: 5 years1128c3 Conviction of two mandatory exclusion offenses. Minimum Period: 10 years1128b1A Misdemeanor conviction relating to health care fraud. Minimum Period: 3 years1128b1B Conviction relating to fraud in non- health care programs. Minimum Period: 31128b2 Conviction relating to obstruction of an investigation. Minimum Period: 3 years1128b3 Misdemeanor conviction relating to controlled substance. Minimum Period: 3 years

1128b4License revocation or suspension. Minimum Period: No less than the period imposed by the state licensing authority.

1128b5Exclusion or suspension under federal or state health care program. Minimum Period: No less than the period imposed by federal or state health care program.

1128b6

Claims for. excessive charges, unnecessary services or services which fail to meet professionally recognized standards of health care, or failure of an HMO to furnish medically necessary services. Minimum Period: 1 year

1128b7 Fraud, kickbacks, and other prohibited activities. Minimum Period: None

1128b8 Entities controlled by a sanctioned individual. Minimum Period: Same as length of individual's exclusion.

1128b8AEntities controlled by a family or household member of an excluded individual and where there has been a transfer of ownership/ control. Minimum Period: Same as length of individual's exclusion.

1128b9Failure to disclose required information, supply requested information on subcontractors and suppliers; or supply payment information. Minimum Period: None



1128b12 Failure to grant immediate access. Minimum Period: None

OIG Exclusion Definitions54

Federal Statute Definition1128b13 Failure to take corrective action. Minimum Period: None

1128b14Default on health education loan or scholarship obligations. Minimum Period: Until default has been cured or obligations have been resolved to Public Health Service's (PHS) satisfaction.

1128b15 Individuals controlling a sanctioned entity. Minimum Period: Same period as entity.1128b16 Making false statement or misrepresentations of material fact. Minimum period: None

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Failure to meet statutory obligations of practitioners and providers to provide' medically necessary services meeting professionally recognized standards of health care (Peer Review Organization (PRO) findings). Minimum Period: 1 year

Ineligible (Proceedings Pending)

Preliminarily ineligible based upon adequate evidence of conduct indicating a lack of business honesty or integrity, or a lack of business integrity, or regulation, statute, executive order or other legal authority, pending completion of an investigation and/or legal proceedings; or based upon initiation of proceedings to determine final ineligibility based upon regulation, statute, executive order or other legal authority or a lack of business integrity or a preponderance of the evidence of any other cause of a serious and compelling nature that it affects present responsibility.

Preliminarily Ineligible(Proceedings Pending)

Preliminarily ineligible based upon adequate evidence of conduct indicating a lack of business honesty or integrity, or a lack of business integrity, or regulation, statute, executive order or other legal authority, pending completion of an investigation and/or legal proceedings; or based upon initiation of proceedings to determine final ineligibility based upon regulation, statute, executive order or other legal authority or a lack of business integrity or a preponderance of the evidence of any other cause of a serious and compelling nature that it affects present responsibility.

Ineligible (Proceedings Completed)

Determined ineligible upon completion of administrative proceedings establishing by preponderance of the evidence of a cause of a serious and compelling nature that it affects present responsibility; or determined ineligible based on other regulation, statute, executive order or other legal authority.

Prohibition/Restriction

May be subject to sanctions pursuant to the conditions imposed by the U.S. Department of the Treasury (Treasury) Office of Foreign Assets Control (OFAC), or subject to a sanction, restriction or partial denial pursuant to the conditions imposed by the U.S. Department of State (STATE) or Federal agency of the U.S. Government.

Voluntary ExclusionAccepted an agreement to be excluded under the terms of a settlement between the person and one or more agencies.

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Legacy EPLS Terms SAM Current TermsCause Nature (Cause)

Treatment Effect

CT Action [Discontinue]

Action Date Active date

Archived Inactive

Agency Contact Agency POC

Permanent [Discontinue]

CT Code Exclusion Type

Classification Type: Entity Classification Type: Special Entity Designation

Address Primary Address

Additional Address Alternate Address

Agency Excluding Agency

Description Additional Comments

SAM Exclusions Terminology • The System for Award Management (SAM) replaced the Excluded Parties List System

(EPLS) in June 2012. When researching an exclusion in SAM, note that certain key terms taken from the EPLS records have been changed to reflect the updated terminology used in SAM.

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CT Codes Description Exclusion Types A1; B; J1; K; N1; O; Q; S; S1; W; Z3 1. Suspension

2. Blocked Pending Investigation3. Proposed Debarment

Preliminarily Ineligible (Proceedings Pending)

08-INA-01; 08-INA-02; 10-VA-01; 10-VA-02; A; AA; C; C1; CC; D; DD; E; EE; F; FF; G; GG; I; I1; J; L; N; P; R; R1; RR; RRR; SS; U; V; Z; Z1; Z2

1. Debarment2. Denial3. Disqualified4. Termination from Eligibility5. Ineligible6. Conviction7. Excluded


03-BSE-01; 03-DP-01; 03-ENT-01; 03-FTO-01; 03-SDGT-01; 03-SDN-01; 03-SDNT-01; 03-SDNTK-01; 03-SDT-01; 03-TLGE-01; 10-CIS-01; 10-ISA-01; 11-USDA-01; BB; BPI-SDGT; BPI-SDNT; BPI-SDNTK; H; H1; H2; JJ; JJJ; M; QQ; VV; VVV; X; XXX; YYY; ZZZ

1. License or Approval Revoked2. Sanctioned3. Partial Denial


T 1. Voluntarily Excluded Voluntary Exclusion

Understanding CT Codes• In EPLS, each exclusion record was identified with a Cause and Treatment (CT) Code. CT

Codes were identified by letters or letters and numbers (for example, H1) and included descriptions of the cause and treatment of the exclusion.

• Original EPLS records now stored in SAM are identified with both a CT Code and an Exclusion Type. The chart below gives a description of each CT Code and also maps it to its related Exclusion Type.

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Exclusion Type Nature (Cause) & Effect

Preliminarily Ineligible (Proceedings Pending)

Nature (Cause):Preliminarily ineligible based upon adequate evidence of conduct indicating a lack of business honesty or integrity, or a lack of business integrity, or regulation, statute, executive order or other legal authority, pending completion of an investigation and/or legal proceedings; or based upon initiation of proceedings to determine final ineligibility based upon regulation, statute, executive order or other legal authority or a lack of business integrity or a preponderance of the evidence of any other cause of a serious and compelling nature that it affects present responsibility.

Effect [on Procurement]:Agencies shall not solicit offers from, award contracts to renew, place new orders with, or otherwise extend the duration of current contracts, or consent to subcontracts in excess of $30,000 (other than commercially available off-the-shelf items (COTS)), with these contractors unless the agency head (or designee) determines in writing there is a compelling reason to do so.


Nature (Cause):Determined ineligible upon completion of administrative proceedings establishing by preponderance of the evidence of a cause of a serious and compelling nature that it affects present responsibility; or determined ineligible based on other regulation, statute, executive order or other legal authority.

Effect [on Procurement]:Agencies shall not solicit offers from, award contracts to renew, place new orders with, or otherwise extend the duration of current contracts, or consent to subcontracts in excess of $30,000 (other than commercially available off-the-shelf items (COTS)), with these contractors unless the agency head (or designee) determines in writing there is a compelling reason to do so.

Defining the Exclusion Type• Records created in SAM (as in, they were not part of the EPLS) are no longer identified with CT

Codes, and are only identified with one of the four Exclusion Types.• The chart below defines each Exclusion Type.

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Exclusion Type Nature (Cause) & Effect


Nature (Cause):May be subject to sanctions pursuant to the conditions imposed by the U.S. Department of the Treasury (Treasury) Office of Foreign Assets Control (OFAC), or subject to a sanction, restriction or partial denial pursuant to the conditions imposed by the U.S. Department of State (STATE) or Federal agency of the U.S. Government.

Effect:If you think you have a potential match with an OFAC listing, please visit the following section of OFAC's website for guidance:http://www.treasury.gov/resourcecenter/faqs/Sanctions/Pages/directions.aspx.For all other prohibitions and restrictions, see the agency note in the Additional Comments field to ascertain the extent or limit on the sanction, restriction or partial denial. If there is no note, contact the agency taking the action for this information.

Voluntary Exclusion

Nature (Cause):Accepted an agreement to be excluded under the terms of a settlement between the person and one or more agencies.

Effect:These persons are excluded in accordance with the terms of their voluntary exclusion agreement. See the agency note in the Additional Comments field to ascertain the extent of the exclusion or the limit on the person's participation, in covered transactions. If there is no note, contact the agency taking the action for this information.

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Exclusion Agency Points of Contact• It is important that you verify a potential match with the excluding agency identified in the

record details. To confirm or obtain additional information, contact the federal agency that took the action against the listed party.

• The Agency Exclusion Points of Contact (POC) page provides an alphabetical listing of federal agency points of contact and their associated contact information, which is publicly available.

• Any question about an exclusion that has been created by someone at the Agency should be directed to this individual.

• To access the Agency Exclusion POC list:• Go to www.sam.gov• Select “Help”• Select “Exclusion Information”• Select “Agency Exclusion POC”

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Term DefinitionBatch Uploading a CSV file of all the names you would like to search is called a batch search. This is the

alternative to individually inputting each name into the single search screen.

Changed RecordAny returned record for a possible match to your employee that was previously cleared by another user in your organization, BUT has changed since the last time it was cleared. All changes to the record since it was previously cleared will be in bold.

CSV File CSV is simply a file format type. All batch search files must be uploaded into ExclusionCheck in the CSV format.

New Record Any returned record for a possible match to your employee that has not been previously cleared by another user in your organization.

Possible Match/Alert

Any non-cleared record that may or may not be your employee. These records have been returned as a possible match to your employee because the name is either exactly the same or very similar. You will need to further research all possible matches to determine if the record is matching to your employee.

Glossary of User Guide Terms

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!EXCLU

SIONS!ATTESTATIO

N!

!All!health!care!entities!are!required!to!screen!employees!and!physicians!against!the!Excluded!Party!List!(O

IG,!GSA,!OFAC,!SDN

,!SAM!or!State!M

edicaid).!Often,!the!inform

ation!listed!on!the!website!is!m

inimal!and!does!not!contain!

enough!information!to!effectively!determ

ine!whether!an!individual!on!the!list!is!the!sanctioned!person.!For!those!

instances,!we!need!to!have!the!em

ployee/physician!attest!that!they!have!never!been!sanctioned/suspended/!debarred/or!had!their!license!suspended!or!revoked!w

ith!any!State!agency!and!have!never!been!sanctioned!by!the!federal!governm

ent.!!Nam

e!of!CHS!Affiliate:!Em

ployee/Physician/Contractor!Full!Nam

e:!Last!Four!Digits!of!SSN

:!Exclusion:!!!Please!m

ark!Y/N!for!the!follow

ing:!!

!!

!!

!!

!Are!you!now!or!have!you!ever!been!sanctioned,!suspended,!revoked!or!debarred!

!by!any!federally!funded!benefit!program?!!

!!

!!

!!

☐!Yes!!!☐

!No!

!!Do!you!have!a!current!valid!license!or!certification?!!

!!

!!

☐!Yes!!!☐

!No!

!!Has!your!license/certificate!ever!been!suspended!or!revoked,!etc.!by!any!state!agency?!☐!Yes!!!☐

!No!

!!Have!you!ever!lived!or!working!in!the!follow

ing!location:!!!

!!

!!

!!

!!

!!

!!

☐!Yes!!!☐

!No!

!!Have!you!ever!had!any!issues!or!have!you!been!on!the!OFAC!(O

ffice!of!Foreign!Affairs!List)?!☐!Yes!!!☐

!No!

!!!!BY!SINGIN

G!BELOW,!I!ATTEST!THAT!THE!RESPO

NSES!I!HAVE!PRO

VIDED!ABOVE!ARE!TRU

E!AND!ACCU

RATE!TO!

THE!BEST!OF!M

Y!KNOWLEDGE.!

!Signature:!_______________________________________________!!Date:!___________________________________________________!

Please direct any questions to the CHS Corporate Federal Exclusion Team

[email protected]

Tracey Lowndes, Sr. Director, ComplianceRobin Boyles, Manager, ComplianceJill Cook, Compliance Coordinator

62

CHSPSC EXCLUSIONS ATTESTATION

All health care entities are required to screen employees and physicians against the Excluded Party List (OIG, GSA, OFAC, SDN, SAM or State Medicaid). Often, the information listed on the website is minimal and does not contain enough information to effectivelydetermine whether an individual on the list is the sanctioned person. For those instances, we need to have the employee/physician attest that they have never been sanctioned/suspended/debarred/or had their license suspended or revoked with any State agency and have never been sanctioned by the federal government.

Name of CHSPSC Affiliate:

Employee/Physician/Contractor Full Name:

Last Four Digits of SSN:

Exclusion:

Please mark Y/N for the following:

Are you now or have you ever been sanctioned, suspended, revoked or debarred by any federally funded benefit program?If “yes”, please explain in Notes section below. qYES rNO

Do you have a current valid license or certification? qYES rNO

Has your license/certificate ever been suspended or revoked, etc. by any state agency? qYES rNOIf “yes”, please explain in Notes section below.

Have you ever lived or worked in the following location: qYES rNO

Have you every had any issues or have you been on the OFAC (Office of Foreign Affairs List)?If “yes”, please explain in Notes section below. qYES rNO

BY SIGNING BELOW I ATTEST THAT THE RESPONSES I HAVE PROVIDED ARE TRUE AND ACCURAGE TO THE BEST OF

MY KNOWLEDGE.

Signature: _________________________________Date:__________________________________NOTES:

63

Community Health Systems Professional Services Corporation (CHSPSC)VENDOR ATTESTATION

1. Legal Business name:

2. Business Address:

3. SSN/TIN of owner/business:

4. The above named business is not currently excluded by the Office of Inspector General (OIG) List of Excluded Parties or The Patient Protection and Affordable Care Act (PPACA) for (reason for exclusion).

5. The above named business has never been provided a notice from or by the OIG or PPACA of a potential exclusion.

6. The above named business is aware that CHSPSC has a policy against doing business with an individual or vendor that is excluded from participation in or receiving federal healthcare funds from any federal or state government or by any state Medicaid Exclusion agency.

7. The above named business is not excluded in the State of __________, or any other state.

__________________________________Printed Name of Vendor Representative

__________________________________Signature of Vendor Representative__________________________________Date

4/20/2016

64

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