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The consequences of not doing screening or of doing screening poorly can be serious. The Office of Inspector General (OIG) can require repayment of funds, Civil Monetary Penalty fines of up to $10,000 for each wrongful submission, plus an additional assessment of up to triple the amount wrongfully claimed. That can really hurt. Keep this in mind. The lists you are instructed by OIG to check--the OIG LEIE and the GSA EPLS databases—work on alphabetical matches. You are very likely to get a false negative result if a slightly incorrect or partially incomplete name is compared to the federal lists. That's why we also look at possible variants in client data and in the federal lists to avoid missing matches. For example, your employee "Ted" is also checked as "Theodore". Likewise, surname variants arising from marriage, divorce and remarriage as well as cultural surname differences are also generated for comparison. Similar compensations occur with the vendor data you send us. We know that your "XYZMed" may be the excluded XYZ Medical Gas, Inc. Our digital systems and human screeners can work together to find the excluded vendor. And there is much more. All tentative matches are researched by our screening staff to determine whether each match is real or not. With your consent, we will even perform on-line queries of the OIG list to test your employee's Social Security Number (see Data Safety) against that of an excluded person. Other research is conducted as required. The GSA database may also be queried on-line for additional details regarding possible name matches. The screener may even contact the listing federal agency for details on the exclusion. Once all this
information is assembled, Sterling senior staff weigh all of these data
and determine the final exclusion status of the tentative
matches. A report is generated showing our exclusion assessment
for each person or vendor you submitted. An executive summary is
generated concisely informing you of our findings. This is signed
by senior management attesting to the completeness of our findings. Both reports are sent you as electronic files and as printed materials. We contact you a few days later to answer any questions you may have. We encourage you to contact us anytime regarding our findings. Back
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