Let’s take a closer look at the DEA Doctor Watchlist, how to access it, and how using it during the screening process can help you make more informed hiring decisions.
The System for Award Management (SAM) is a US government portal for businesses, organizations, and federal agencies to win government contracts. However, its lists of excluded individuals and entities can also help healthcare employers with hiring decisions. Using SAM can be complicated, but healthcare sanction checks can simplify the process. Find out more.
What Is The System For Award Management?
The System for Award Management—called SAM—is a US government-owned and operated website and portal. In the simplest terms, it’s a free tool for businesses, organizations, and federal agencies to win contracts and work with the US government (and for the government to award those contracts to current and potential vendors—hence the name Award Management).
SAM was developed in 2012 when the General Services Administration (GSA) consolidated several federal award and procurement systems into one system. This was done to streamline processes by eliminating duplicate data entry efforts, improve quality data, and—ultimately—save taxpayers money. In addition to that, though, SAM is also used to:
- Update or renew your entity registration
- Check the status of an entity registration
- Search for entity registration and exclusion records
- Find sources about federal acquisition and procurement
- Find information about acquiring financial grants and cooperative agreements
Of course, the entire process of using SAM is quite a bit more in-depth than that. That’s why GoodHire is sharing information for employers in the healthcare industry about SAM, and what you need to know about hiring and screening federally contracted employees.
How Is SAM Used?
First, to be awarded contracts by the US government, vendors must be registered in SAM. Part of that registration includes providing in-depth information for procurement and any financial transactions. Once that’s complete, vendors must update or renew their registration every year to keep an active status.
But SAM isn’t just used by vendors; it can be used by anyone who wants to do business with the US government, including:
- Contractors, federal assistance recipients, and other potential award recipients—called entities—looking for opportunities or assistance programs and for reporting subcontract information
- Officials who are responsible for contracts, grants, performance reporting, suspension, and debarment
- Members of the public searching for government business information
SAM can also be beneficial to businesses—essentially used as a marketing tool to advertise their business. That’s because agencies and contractors can search for businesses in SAM based on size, location, ability, experience ownership, and other factors.
What’s more, SAM contains information from the Online Representations and Certifications Application (ORCA)––which is another federal government web-based system that requires vendors to provide even more detailed information, like travel policies and accounting procedures. Why is this information relevant? To ensure that businesses, firms, and contractors meet federal requirements.
Finally, SAM is often used as a recruitment tool. Federal, state, and local government agencies use SAM to find contractors and subcontractors themselves—instead of the other way around.
How Does SAM Help Healthcare Employers With Hiring?
One of the most crucial features of the integrated SAM system is what’s called an exclusion list. Just as SAM houses a list of contractors and entities approved to work with the federal government, it also includes a list of contractors and entities excluded from working with the government. These are also often referred to as suspensions or debarments.
Those marked as excluded within SAM may be so temporarily and for several reasons, including:
- Violating antitrust statutes
- Delinquent federal taxes (anything more than $3,000)
- Commission of fraud, embezzlement, theft, forgery, and bribery
- Violating the Drug-Free Workplace Act
- Failing to disclose violations of criminal law, and more
Another exclusion list—called List of Excluded Individuals/Entities (LEIE)—is managed by the Office of the Inspector General (OIG). Contractors may also be on this list for a number of reasons, including:
- A conviction of Medicare or Medicaid fraud
- Patient abuse or neglect
- Felony convictions for healthcare-related fraud, theft, or other financial misconduct
- Felony convictions relating to the unlawful manufacture, distribution, prescription, or dispensing of controlled substances
While there is some overlap of the SAM and LEIE exclusion lists, there are also differences of which employers need to be aware.
First, each of the exclusion lists is managed by different agencies (the OIG and the GSA), which means they have unique administrative processes. Second, the search process for each is different, too—each presenting unique challenges for employers. How?
The SAM exclusion list doesn’t provide license information or National Provider Identifier (NPI) records of those on the exclusion list—which are needed to verify that your search results actually match the candidates you screen. As a result, if an employer finds a candidate or contractor marked as excluded, they have to contact the federal agency that created the record to verify the results—a process that can take a lot of time.
What Steps Should Employers Take Beyond Using SAM?
While SAM and LEIE can be highly beneficial to healthcare organizations, they can also be challenging for employers to navigate, creating additional risks during the screening process.
First, going through all of the steps required during the screening process can be challenging and time-consuming. Navigating different databases, checking the SAM exclusion list, verifying information with other federal agencies, checking the LEIE, ensuring you have the right candidate’s information…all of this costs employers and their staff time, which also costs money. This is especially true for healthcare entities that hire and contract hundreds or thousands of people a year.
What’s more, employers that don’t thoroughly screen candidates face several consequences, including:
- Becoming excluded from participating in federal programs like Medicare and Medicaid: Hiring an excluded worker puts companies at risk of losing funding through these programs.
- Paying costly penalties: Organizations may be penalized heavily—up to $10,000 for each item or service provided by the excluded employee.
- Compromising patient safety: If a candidate is on the excluded list because of patient abuse or neglect, employers risk the same thing happening to their patients.
- Risking financial misconduct: If an excluded candidate has been convicted of fraud or theft, employers put their organization at risk as well.
Finally, there is a risk of non-compliance during the screening and hiring process, if performed incorrectly. Because there are several laws, regulations, processes, and guidelines to adhere to (including those outlined by the FCRA), employers trying to navigate exclusions checking on their own may increase their risk of non-compliance.
As a result, employers should always take an additional step when screening candidates by conducting healthcare sanctions checks through a reputable employment screening provider like GoodHire.
Practice Smarter & Safer Hiring With Healthcare Sanctions Checks
As part of a comprehensive background check, healthcare sanctions checks screen candidates for you, streamlining the entire hiring process while providing in-depth results. Depending on your requirements and the level of search you use, a sanctions check may search more than 1,000 government sources for any penalties, suspensions, or punitive or disciplinary actions against a healthcare professional. Different levels also include the OIG and SAM exclusion lists to tell you whether a candidate has been or is excluded.
In addition to learning about a candidate’s status, you’ll also verify:
- The name of the source or board that took the disciplinary action
- Whether the sanction is currently active
- The end dates of any previous sanctions
- The violation or reason for the sanction (if available)
- Whether an employee has been recently added to an exclusion list (provided through an optional Ongoing Alerts add-on search)
It’s also crucial to remember a healthcare sanction check goes beyond a typical background check for candidates, helping you:
- Maintain eligibility for Medicare, Medicaid, and other federal programs
- Avoid OIG penalties of up to $10,000 for every day the excluded individual worked
- Reduce risks to your patients, your staff, and your organization’s reputation
Find out if your healthcare candidates are in good standing. GoodHire offers healthcare sanction checks and hundreds of employment screening services.
The resources provided here are for educational purposes only and do not constitute legal advice. We advise you to consult your own counsel if you have legal questions related to your specific practices and compliance with applicable laws.