Joey: So I am here today with Beverly Lindstrom, who is the Chief Operating Officer for pre-employ.com. Thank you so much for coming, Beverly.
Beverly: Thank you for having me, hello.
Joey: Today, we wanted to talk about a product offering called FACIS 1M. FACIS is the Fraud Abuse Control Information System. Beverly, can you explain what FACIS 1M actually is?
Beverly: FACIS 1M is a proprietary product powered by Verisys, that Pre-employ is offering. It is a powerful tool that includes not just the OIG, Office of Inspector General, LEIE List, but also SAM, which those are the two primary components for federal funding. It includes the direct searches of the Department of Justice, OFAC, FDA, a whole bunch of them on the federal level, plus the 35 state Medicaid exclusions. And so it’s a very powerful healthcare sanction tool and service that is just tremendously more robust than the OIG alone.
Joey: So it’s on… It’s everything that you would get with the OIG, plus a whole bunch more?
Beverly: Exactly. For the healthcare industry, it meets the OIG compliance requirements for federal Medicare and Medicaid funding. It also includes all the other state-level sanction searches that are needed for the state-level funded. Whether it’s federal, giving the money to the state, state distributing it, or state having their own funds for healthcare, or other non-federal funds, this product meets and exceeds most, in almost every case, all of those requirements for the funding.
Joey: So if we’re doing FACIS 1M, we’re guaranteed the OIG, we’re guaranteed the other sources. I noticed when you talk about FACIS 1M, you oftentimes say, “FACIS 1M plus monitoring.” Can you explain that? What’s the monitoring portion of it?
Beverly: Sure! So the monitoring, the FACIS 1M or the OIG, the standard process is usually it’s required to be at least monthly that you check the healthcare sanctions lists. At least monthly means most entities that aren’t involved in a monitoring program, send a list once a month to their provider. Or their internal administrative staff once a month searches every person that works in the company that is subject to this. That’s potentially a 30-day gap that you’re checking that list for anything that happened the day before.Monitoring is real-time. An event happened yesterday and somebody is put on the list because of an action. If that entity checked the list the next day, it could be 30 to 60 days before they actually find out that information that such person is on the excluded list. That’s a big vulnerability because the healthcare funding is dependent on making sure that you don’t have anybody who’s on the exclusion list providing services.
Joey: So now, do you have any idea of percentages of how many licensed professionals are on the exclusion list?
Beverly: Well, just on the LEIE alone, the Office of Inspector General… Make sure I’m filling out the acronyms… There’s over 70,000 individuals just on that single list. When you multiply that times the 40 other lists that are required along with the state and other exclusions, which can be up to the 300, that could get exponential.
Let’s just take, for example, in California. At a given time, 16% of the people on exclusion list might be physicians, 40% are nurses, nurse practitioners. So it’s a tremendous amount of persons in your industry and across all of the positions that need to be screened to make sure that you’re compliant with it.
Joey:It reminded me of a quote that you hear in a courtroom or law enforcement is, “Ignorance of the law is not a defense.” So saying, “Oh well, we check OIG once a month and that hadn’t bubbled up to OIG.” that’s not gonna help you.
Joey: They’re just gonna say, “Well, too bad.” Right?
Beverly: Yes, absolutely! Even the Office of Inspector General has said there’s an obligation to check the individual state list and all of the federal applicable department and healthcare sanctions. So ignorance of the law does not excuse it. If you’re debarred from one, you’re debarred from all. And just because you only checked one list, that doesn’t get you out of it. They all need to be checked.
Joey: Give me some idea of the funding potential loss here. If you had a nurse or a nurse practitioner, something like that on staff. They were on that exclusion list. You don’t know about it because you’re only using OIG. That data’s not… Like you said, it could take months to propagate. And then, it comes out okay. You’ve had this person on payroll. You’ve had this person dealing with patients for the last month. Do you have any idea like what kind of funding loss that could potentially be?
Beverly: Oh yeah, it’s huge. So the HHS will fine up to $10,000 for each item or service provided by an excluded person. So if a nurse aide provided services for a full month and turned out they were on the exclusion list, that would be 10,000 for each service that she provided in that. So during a 29-day lapse, if she serviced 100 people, that can literally be $10 million in loss of funding and penalties.
Beverly: That’s a huge amount. And when you look at the risk factors, three out of every thousand health care workers are on the list or seven out of every thousand have been on the list. Ten out of every thousand have a revoked license. They’re not huge numbers but they’re very expensive numbers, and they’re significant.
Joey: No, absolutely! That’s probably why this is something you have to be careful of is because it only takes one on that exclusion list. It’s not like, “Oh, you know, 20% of your staff is on exclusion list.” It’s like, “No, you just had two employees that were on that exclusion list. You didn’t know about it but you have that liability.” And I think a nurse touching 100 people in a month is a really low number. I unfortunately found myself in a hospital. A nurse touching 100 people might be a slow week. So I can only imagine in a major organization, these numbers can just be astronomical.
Okay, you sold me on the value of this real-time monitoring. Normally, I think a lot of these healthcare organizations. They’ll be uploading these lists each month. With this system, when you talk about monitoring, this must be like, what? Add it one time, and it’s saved, and monitored automatically?
Beverly: Well, we have the ability to work with whatever your existing system is that you have for payroll. So if you wanna send a one-time list or provide your single list, and then just provide your active employees each month thereafter, that’s great. If the preference is a single first time list and then just provide the added new hires or terminations of employees, that would work too. So it’s a complex searching the fastest, but implementing our program is not. It’s very easy and we’ll work with whatever your situation is.
Joey: Well, two things that’s gonna do. Number one, that’s gonna potentially cut down a lot of administrative overhead. If I heard you right, if I only have to provide my employee list one time, and then I just give you the changes, like we had a couple of nurses leave, we added a physician, a medical assistant, things like that. That’s gonna make my administrative overhead substantially less. And also, I think quality assurance is going up because if I have to aggregate a list every month then the potential to let somebody fall into the cracks just goes up. Many time, production goes up, quality assurance goes down. So do I understand that right? I could just provide you that list and then provide you changes on a monthly basis?
Beverly: Absolutely. And you touched on the administrative overhead. Whether you’re doing it in-house, and you have your own staff or an entity has their own staff checking that one 240, 293 list every month, that’s significant.Eliminating that is a significant savings. Or even if you are outsourcing to an entity for a single search or even multiple, it’s still the administrative of your internal staff going through those monthly reports that come back.
With the real-time monitoring, they only have to look at those where there is a potential record or a potential person. The rest is saved. It’s compliant. You’ll have your reports but you only need to be alerted when there’s a change. However, it best works for that entity. We can set up the system to meet your compliance, your regulatory, and your reporting requirements. But, it only alert the persons when there’s something they need to see. Or if you wanna see it every time, that’s fine. We can do that too.
Joey: You know, that sounds like it’s gonna reduce costs. When you were talking, I thought about the larger health organizations that span multiple states, that have hundreds if not thousands of employees. The administrative overhead of getting that, the logistics of ensuring that those lists are correct, this can clean up so much of that. I can’t remember the exact percentage. Maybe you’ll know this, but it’s like the number of states exclusion lists that do not get reported up to the OIG. It’s pretty high, right? It’s not just like one or two states. It’s a big number, right?
Beverly: It’s half.
Beverly: Yeah, it’s a big number.
Joey: So half the states do not report up to the OIG. If you think you’re being covered by OIG alone, and you operate in multiple states, you might be in for quite the shock if your employees get on that exclusion list?
Beverly: Yeah, especially as it relates to state level funding or any of those. Yeah, it can definitely be a big risk and a big gap in the 30 days as well.
Joey: Okay, so we clearly see the value now. Magnitude’s more powerful than OIG alone. The constant monitoring, the ease of use. So now here comes the poison. How much more expensive exponentially is this than OIG, right?
Beverly: Mm-hmm. So it is often less than but usually always same price as you’re paying for a single search for an OIG only. We can implement this program usually at the same price, sometimes less. It’s going to be a seamless transition as well. So less cost, less overhead, same price, sometimes even less than you’re paying now.
Joey: Well, then that’s a no brainer. I find that hard to believe, but that’s awesome. Maybe that’s just what happens when you get automation in place and you clean up some of the manual uploading. You’re gonna see economies of scale, and that’s what that sounds like. Now I know Pre-employ is offering. I see here that they’re offering up to a half a million dollars. Can you kinda explain what that means? What’s half a million dollars? Are they gonna stroke a check or what is that?
Beverly: Yeah. Obviously. The half a million dollars is available in service credits for our FACIS 1M implementation. This means that if Pre-employ can provide your background screening services and bundle that with the FACIS 1M, service credits can be applied to the FACIS 1M. So that in many cases, there now is no cost for you. That half-million dollars can go towards that what you would be paying to outsource that, or our I9 E-Verify.
If you just love your source for your healthcare sanctions, and you don’t want to change. Maybe you have a provider that you feel like you’re good with. That’s fine. We still believe that we can meet and/or beat the price of that. But that half a million can still go towards that I9 E-Verify service credit. So definitely would like to look at the whole program or just the individual components of FACIS 1M or I9 E-Verify.
Joey: Wow. So then the point of this is that if you’re an HR director, if you’re in compliance, or if you’re a chief financial officer trying to figure out where you can cut costs and not cut service, you should be talking to somebody from Pre-Employ. You should call Pre-Employ (530) 633-6574. You can also use the contact form that can get you someone that can. They could sit down with you, or like over a Zoom call or something like that. They can give you the cost calculation, right? They can show you what you can save, and the bundling opportunities that Pre-employ offers?
Beverly: Yeah. Absolutely. And if it’s being done in-house and being administrated. The healthcare sanctions in-house, even that small discussion of the varying identifiers across the list. The way different URLS you have to go to, and some sites provide those matching identifiers, others provide this information. It can be quite a bit, even for the internal. And so quantifying that to say how much does it cost to administrative internally? Well, it’s a function of staff every month. It’s a lot, and it’s a risk if it’s not done 100% correctly.
Looking at it from internal, or if you have an external provider, still we’d love the opportunity to speak with you. We do believe we can meet and/or beat your full background screening needs or just the individual components of FACIS 1M or I9 E-Verify.
Joey: Fantastic. So to recap. We’ve got FACIS 1M, which is the OIG monitoring, plus almost 300 more data sources, with monitoring. It’s in real time. So you’re not waiting three months for the state to upload the exclusion list. And that’s if you’re in the 50% of the states that actually report to the OIG. If you’re in one of those states that doesn’t report, you really need to look into this.
On top of that, this is potentially at no more cost. Depending on how you bundle your employment screening with I9 and E-Verify and some other things, this is potentially no cost or pennies per. On top of that, Pre-employ is offering up to $500,000 worth of services free if you bundle some of your employment screening. Did I get everything?
Beverly: You did. The products are powered. Verisys powers the FACIS 1M. We’re a designated agent for Department of Homeland Security, E-Verify. So these are strong products with industry knowledge of what you need. You can feel comfortable that your services are being performed by leaders in the industry.
Joey: Fantastic, Beverly. Thank you so much! So if you’re an HR director, if you’re a compliance officer, if you’re maybe even talent acquisition and you wear multiple hats, or you’re a chief financial officer, and you’re trying to figure out a way to cut cost without cutting services, fill out the contact form below or call (530) 633-6574. Somebody from Pre-Employ can tell you, break down the numbers for you, and give you an honest estimate. So thank you so much for your time today, Beverly. Really appreciate the education, and you have a wonderful day.
Beverly: Thank you. Thank you for having me.
The Fraud and Control Information System (FACIS) is a database search of records containing adverse actions against individuals and entities sanctioned in the healthcare field. This includes information on disciplinary actions ranging from exclusions and debarments to letters of reprimand and probation.
Healthcare sanctions checks generally include a search in a registry of disciplinary actions taken by federal, state and licensing boards and certification agencies. The search results may include debarments, exclusions, probation, and letters of reprimand.
Also referred to as “healthcare sanctions”, medical sanctions are exclusions which are levied against certain individuals or entities from participating in federal healthcare programs. The individuals are usually healthcare professionals. The entities are usually organisations which provide healthcare-related services.