Integrity

LEIE and SAM screening for a public health laboratory

42 CFR 1001.1901 is not only a hospital rule. If federal program funds touch the work, exclusion screening is part of the quality system.

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The obligation

No payment may be made under Medicare, Medicaid, or other federal healthcare programs for items or services furnished, ordered, or prescribed by an excluded individual or entity. Screening extends to employees, contractors, and certain vendors. LEIE updates monthly. SAM is complementary.

A PHL-shaped workflow

Screen at hire and on a monthly cadence. Log the list, the date, the reviewer, and the disposition of any hit. Do not keep that log in a private inbox. It is a survey artifact and, if something goes wrong, an OIG artifact.

Global Hands can support the workflow and the evidence package. It does not itself bill federal programs or perform testing.

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