A Free Pass – PART 1. How three part last names give a free pass on the OIG LEIE online search.
A prospective employee has a last name of “De La Cruz”. You search this last name and no results. Sound good? Hold on a minute. There are several excluded people with this last name. See for yourself in the download file. Better yet, shorten it to just “De La”. Interestingly, there are indeed people with the full last name of De La Cruz but the online search give them a free pass if you use their full last name.
How? Look at what it says was the entered last name. “DE LACRUZ”, not “DE LA CRUZ”. The second space in the last name disappears. And so does the exclusion notification earning this individual a free pass.
What am I to do and what does the OIG say about this? They recommend “The simpler you can make your search, the better. When searching for the name of an individual, enter only the first few letters of the last name.” Source https://oig.hhs.gov/exclusions/exclusions-help.asp#generalSearch
Obviously a good work-around but in practicality who wants to wade through numerous listings since only a few letters were entered? Most people are worried about the possible alternative first names that each need to be entered. Now if you can’t trust the first name or the last name, you really have your work cut out for you.
And what about first names? Check back soon for part 2 of the “Free Pass”.
As always, be careful who you put your TRUST in for your provider and employee ongoing exclusion monitoring. Have questions? Ask the experts on exclusion monitoring. John Sterling Associates, LLC.