How are they used, and how can they fall short?
By working with the US Dept of Health & Human Services (HHS) Office of Inspector General (OIG) for over a decade, Verify Comply has insights that only a vendor working in the industry can obtain. If you’re currently using or intend to use the List of Excluded Individuals and Entities’ (LEIE) downloadable files, this is a must read. With the goal of improving the LEIE, Verify Comply has worked with HHS Senior Counsel and has a great relationship with the agency. Our goal is to educate and bring awareness into how it should be used and to several interesting and potentially concerning shortcomings.
Full File vs Monthly Supplements
The available versions of the downloadable LEIE database are:
- Full File
- Monthly Supplements
The LEIE full file is just that – it’s a mostly complete (more on this later) file that’s intended to be used as a full replacement. On the other hand, the LEIE Monthly Supplements come in two flavors:
- Exclusions: This file contains new additions to the LEIE.
- Reinstatements: This file contains records recently removed from the LEIE.
A common misconception is that applying current Exclusion and Reinstatement Supplements to a prior Full File leads to a current database, or to view it in a different way:
This seems simple enough, however, this logic is flawed. How you ask? Because it does not take into account changes/edits to records in the LEIE. This is where the Profile Corrections document can help.
LEIE Profile Corrections: What are LEIE Profile Corrections? How is the LEIE Profile Corrections document used?
If we include the Profile Corrections, then: prior month Full File plus current Exclusions Supplement minus current Reinstatement Supplement equals the current LEIE full file, right?? Well, no again...and this is where it starts to get a little hairy.
While the Profile Corrections document is intended to be a comprehensive list of changes, it’s often not accurate. We’ve learned that the Profile Corrections document is manually maintained by the HHS, so it’s quite error prone. Even more concerning than human error is that SSN changes weren’t even reflected in the Profile Corrections document until Verify Comply brought this gap to the OIG’s attention a few years ago. So you could have used the LEIE’s web search to rule out a match using the SSN, only to have the SSN change at a future date and create a hidden liability. Pretty scary, eh? Thankfully, it seems this gap has been addressed by the OIG.
What problems exist with the LEIE downloadable files?
LEIE Deceased individuals. And we’re not just talking a few - at the time of writing of this article, there are still over 5,000 deceased individuals in the LEIE. Verify Comply brought this to the HHS’s attention years ago and provided a list of deceased individuals by comparing it against the Social Security Death Master Index (Verify Comply offers Death Master searches), but it remains an issue.
LEIE Misspelled names. We all make mistakes, right? While this doesn’t occur often in the LEIE, it does happen. There isn’t an easy or perfect solution to this issue, but we’ve developed a pretty great option. After a great deal of time & effort, we’ve mined the majority of the SSNs for individuals on the LEIE. This enables a feature we call DeepScan that allows us to match directly on the SSN. The feature often identifies mistakes in either our customer’s data or the LEIE and uncovers hidden liabilities.
Okay, so that’s gotta be it, right? Nope!
LEIE Truncation. The LEIE’s data file extract uses fixed width columns. When a value exceeds the length of the field, it’s simply cut-off – or truncated. This is most often the case with the Entity Name filed. An example is “MINI TRANSPORTATION WHEELCHAIR AMBULANCE SERVICE”. If this term is searched in the LEIE’s web search, it will yield a result. However, it will not show at match in the downloadable data because the datafile is limited to “MINI TRANSPORTATION WHEELCHAIR”.
Does your exclusion vendor or internal system effectively handle LEIE truncation? It’s simple enough to check - just search “MINI TRANSPORTATION WHEELCHAIR AMBULANCE SERVICE” and see if an LEIE match is found. If not, there’s a gap.
HHS Debarment. Did you know the US HHS OIG has another sanction list that’s separate from the LEIE? HHS Debarment records aren’t in the LEIE. However, they are in the US General Services Administration (GSA) System for Award Management (SAM). By including the SAM in your searches, you’ll capture HHS debarments, and you’ll also see the records with truncation issues mentioned in the previous section. So for these reasons it’s a good idea to search the SAM, even if you’re not required to do so.
If you’ve made it this far, you’re as exhausted reading this as I am writing it. The summary is, effectively monitoring exclusions isn’t as easy as it seems at face value – and above is just ONE of the nearly 70 datasets we offer. Verify Comply has spent over a decade analyzing and improving our processes to yield peak results for our customers, and by scoping our services solely to exclusion monitoring (no licensing or credentialing), we offer the highest-level expert services for industry low prices. Efficient. Effective. Affordable. – it’s how we roll!
If you’d like to find out how we can make exclusion monitoring easy for your organization, give us a call at 855.937.2872 x1, write us at orders@verifycomply.com , or submit a request online.
