UAMS ADMINISTRATIVE GUIDE                               _
 NUMBER:    15.1.1                                                                           DATE: 12/13/2006    
 REVISION:                                                                                        PAGE: 1 of 3

SECTION:

   INSTITUTIONAL COMPLIANCE

AREA:

   GENERAL ADMINISTRATION

SUBJECT:

   EXCLUDED PARTIES POLICY

PURPOSE

To ensure that UAMS does not employ or do business with individuals or entities excluded by the U.S. Government from receiving Federal contracts or certain subcontracts or from certain types of Federal financial and nonfinancial assistance and benefits.

SCOPE

All UAMS employees, volunteers and vendors of UAMS.  Vendor includes all persons or entities having contracts with or otherwise doing business with UAMS.

POLICY   

UAMS will not employ, or contract with, individuals or entities listed by a federal agency as debarred, excluded, or otherwise ineligible for participation in federally funded health care programs.

PROCEDURE

All employees, contractors and applicants selected for positions with UAMS will be reviewed with state and federal licensing and sanctioning authorities including the OIG sanction list, and the General Services Administration (GSA) Excluded Parties List System (EPLS).

Vendors and Contractors:

  1. The Database Management Team in Procurement Services will create a new vendor setup in SAP as requested by requisitioners, AP technicians and medical buyers on a daily basis.  The Excluded Parties Listing System (EPLS) Reciprocal list and the Procurement/Nonprocurement list will be downloaded from the federal government’s online EPLS website daily by the Database Management Team.  As new vendor setups are requested, they will be matched against the EPLS download.  Matches will be reported to the Institutional Compliance Office.
  2. Each month, the Institutional Compliance Office will obtain the current vendor list online from the SAP system.                                                                                                     
  3. The Institutional Compliance Office will download one database from the federal government’s EPLS which includes both the Reciprocal list and the Procurement/Nonprocurement list. 
  4. The Institutional Compliance Office will match the UAMS vendor list to the list downloaded from the EPLS website. 
  5. The Institutional Compliance Office will research potential matches.  The Institutional Compliance Office will inform the Contracting Office, Office of General Counsel and the appropriate compliance committee of any vendor matches.  The affected departments shall report the termination of the business relationship with the excluded vendor to the Institutional Compliance Office.

Employees and Volunteers:

  1. During the hiring process, the UAMS Office of Human Resources (OHR) will enter the name, as well as any known aliases, of any individual with a felony on their criminal background check into the online Office of the Inspector General’s List of Excluded Individuals/Entities database. 
  2. Additionally, OHR will enter the name of recently hired employees into the online searchable database. 
  3. For each potential match, the OHR will verify by entering the individual’s social security number and date of birth.
  4. If a match is found, the OHR will immediately notify the Institutional Compliance Office.  The Institutional Compliance Office will notify the Office of General Counsel and the appropriate compliance committee.  The excluded employee’s supervisor and OHR will ensure that the individual’s employment is terminated as soon as possible.  OHR shall notify the Institutional Compliance Office of the date of termination.
  5. If a match is found and the employee has not begun employment, the individual will not be employed by UAMS.
  6. As an additional safeguard, on a monthly basis the Institutional Compliance Office will obtain the current campus employee listing from the OHR and compare the campus employee listing to the downloaded list of excluded individuals/entities from the OIG’s website.
  7. Any potential matches will be researched by the Institutional Compliance Office for action in accordance with the procedure above.
  8. As new volunteers offer their services to UAMS, the UAMS Medical Center Department of Volunteer Services and ACRC Department of Volunteer services will send the volunteer’s name to the Institutional Compliance Office. 
  9. The Institutional Compliance Office will then check the potential volunteers against the OIG’s website to ensure that the individuals are not excluded parties and notify the applicable Volunteer Office whether the individual is eligible to serve as a volunteer at UAMS.

College of Medicine, Faculty Appointments

  1. After receiving approval from the Dean’s office to move forward with the recruitment, the department must take steps to insure that the potential faculty has no outstanding medical-legal issues.
  2. Two databases, www.oig.hhs.gov and http://epls.arnet.gov , must be checked to determine if there are any outstanding medical-legal issues that would prevent the provider from being eligible in any federally funded health care program.
  3. The department designee will search the exclusions database using the first and last name of the provider.  The search results page will be sent to the UAMS Credentialing Office. 
  4. The department designee will notify the UAMS FGP Compliance Officer of any potential matches.  The UAMS FGP Compliance Officer will research any potential matches and notify the UAMS Vice Chancellor for Institutional Compliance of any discrepancies. The affected departments shall report the termination of the potential employment relationship to the UAMS FGP Compliance Officer who in turn will notify the UAMS Vice Chancellor for Institutional Compliance.