Author: Questin Francis

COVID-19 Update

We have received several inquiries regarding Typhoon Data’s status given the COVID-19 pandemic. We are therefore providing this update to our partners to put them at ease and to help them understand our current mode of operation.

Typhoon Data remains fully operational. All Typhoon Data employees were relocated to work from home when Utah Governor Herbert made the recommendation weeks ago. We were able to do this in a way that did not compromise our production, quality, or security. Our business continuity plan has always included work from home provisions and policies which have been followed with great success. Additionally, our employees have been provided technologies and tools to make their remote working environment collaborative and effective.

Thankfully, Utah has not yet been hit as hard as other areas of the country. Our hearts go out to those in New York and other areas where the spread of COVID-19 has been much more severe. We have had several partners inquire if we are able to take on additional work as they have had other avenues diminish in production capacity. We do have available bandwidth to assist in these circumstances and can be contacted to discuss any special needs.

Given the need to focus on COVID-19, we are seeing (and expect to see more) boards holding off on standard meetings and procedures to allow healthcare workers flexibility to adapt to the changing demands in healthcare. We are still seeing new records come to the system each day, however, we expect that overall numbers will be smaller than usual coming from healthcare boards.

Additionally, Typhoon Data has released special temporary products and pricing to assist Healthcare organizations in qualifying providers quickly during the demand COVID-19 has created. All customer, product, and strategic plans are continuing forward. Please feel free to reach out to us with any questions through your normal sales or customer service contacts.


Best Regards,
Typhoon Data Team

SAM.gov Exclusions – What Are They, and Where do They Come From?

SAM.gov publishes an exclusion file used by many organizations for screening and/or compliance purposes. This exclusion file replaces the former EPLS files as of November, 2012. The SAM exclusion file receives regular updates and contains the collective exclusion reporting of over 80 different federal agencies totaling to approximately 130,000 exclusion records. An exclusion record from SAM.gov indicates that the individual or organization listed is disqualified from receiving any federal government contracts. S.A.M. stands for System for Award Management. This system is used for any party seeking to be awarded a federal government contract and become a federal vendor or supplier.

Let’s take a look at the break-down of the SAM.gov exclusions to see where most of the information comes from. As seen in the chart below, almost 1/2 of the SAM.gov exclusion records come from the Department of Health and Human Services’ OIG LEIE exclusion list. The top 6 contributors to the SAM.gov file makeup over 90% of its total records. The chart below only shows the top 27 federal agencies that report to SAM, there are many more which have made small record contributions.

Each agency that reports to the SAM exclusion system is responsible for the accuracy of its records and the information they contain. Exclusions records have a “type” and a “termination date”. The types are generally “Prohibition/Restriction” or “Ineligible”. In some cases the type may indicate “Proceedings Pending” or “Proceedings Completed”. These types give a little insight into the status of the investigation resulting in exclusion. The termination date in the record indicates the shelf-life of the exclusion. In some cases, a future date is present. This means that once that date is reached, the party on record is no longer excluded. In many cases, the word “Indefinite” is seen in the termination date. An indefinite exclusion never expires and can only be removed at the digression of the reporting agency. If specific conditions or criteria are met, the excluding agency may remove the exclusion. SAM does not publish a reinstatement list, non-excluded parties are simply removed from the updated file. Some reporting agencies (such as the OIG) do maintain their own reinstatement lists.

 

SAM Pie3

TyphoonDATA offers data and compliance solutions that include the SAM.gov exclusions file and much more.

To speak with TyphoonDATA directly, please contact:

Richard Rupert, VP Compliance Solutions
Office: 800.780.5901 extension 705
rrupert@typhoondata.com

Top 5 reasons why providers make the OIG Exclusion List

It is a common assumption that the majority of providers on the OIG List of Excluded Individuals/Entities (LEIE) arrived there by defrauding the Medicare/Medicaid systems. It turns out that program related crimes are the second most common reason for exclusion. The most common reason why providers are excluded is due to license revocation or suspension. Below are the top 5 exclusion types and their descriptions:

OIG_breakdown

Drilling down on why a given provider’s license was revoked or suspended is not always easy. The reasons for these revocations and suspensions are many. Often times, the notes or minutes coming from the state licensing board do not specify a reason as the relinquishment may have been voluntary. Additional digging is often required to get the full picture.

Let’s look at an example:

Malissa Bender, was recently excluded on the OIG List. She was excluded because the Florida Board of Pharmacy granted a “Voluntary Relinquishment of License” tendered by the provider in October, 2013. Additional internet research reveals that Bender was arrested in July 2013, for stealing schedule II and III drugs from the Pharmacy where she worked. (see story)

With over 25,000 providers excluded for type 1128b4 you can see how tedious case-by-case research can become to get to the bottom of each exclusion. Fortunately, in most cases, simply knowing that the provider’s license is suspended or revoked should be enough for most employers to take action. In some cases, the reason for revocation or suspension will not be due to criminal action, or any other reason known to the employer. This fact emphasizes the need for employers to monitor an employee’s license and exclusion status.

TyphoonData offers solutions for license and exclusion monitoring.

If you would like to discuss our thoughts and solutions, give us a call at 800-780-5901.