Government agencies keep official lists of individuals and organizations known to operate risky or illegal business operations. As a hospital, it’s up to you to check your own compliance and make sure you aren’t working with these entities.
Not only will you mitigate the risk of fines and sanctions, but you are also protecting the health and wellbeing of your patients, in addition to advancing the business goals of your organization.
In order to meet compliance requirements screening business partners and staff against denied party watchlists is the best first step. Among those that healthcare organizations need to pay attention to is the one provided by the General Services Administration (GSA), specifically the SAM exclusion list. Read on to learn more about GSA compliance and exclusions screening.
GSA, EPLS, and the SAM Exclusion List
While GSA compliance is not the only component of an overall healthcare compliance program, it still plays a significant role in the efforts companies make to comply with rules and regulations. Let’s start by clearing up these acronyms.
- The General Services Administration (GSA) is the governing body responsible for the SAM exclusion list, which identifies parties who are barred from receiving federal contracts. (And the GSA itself is a provider of centralized procurement for the U.S. Federal Government).
- The original format of the list was known as the excluded parties list system (EPLS).
- This list later evolved into the System for Awards Management, also known as SAM, under the Affordable Care Act.
While the EPLS and SAM aim to achieve the same goals, SAM included a few noticeable improvements to help healthcare businesses find the exclusions they need and properly screen employees and vendor partnerships.
How Does the SAM Exclusion List Differ From EPLS?
Among other changes, the SAM exclusion list simplified the search function significantly by using a single name search with automatic suggestions as you type. EPLS search involved separate sections for searching based on name, SSN, and Tax Identification Number.
Also, under SAM, exclusions are grouped based on the following categories that replace the old cause and treatment (CT) codes:
- Ineligible (Proceedings pending or completed)
And finally, a new type of party to search for is the “Special Entity Designation,” essentially a miscellaneous category. The same ones from EPLS are still available here, such as Firm, Individual, and Vessel.
What Is SAM Used For?
The SAM exclusion list was originally developed to consolidate several federal systems into one centralized repository. The EPLS is actually only one component of the SAM regime, which also includes the following databases:
- Central Contractor Registry (CCR).
- Federal Agency Registration (Fedreg).
- Online Representations and Certifications Application (ORCA).
SAM intends to streamline data entry and quality, resulting in a less complicated way for businesses and the public to reference the lists. In addition to checking on exclusions, you can also use SAM to:
- Update your entity registration and check the status of your progress.
- Acquire financial grants and cooperative agreements.
- Find sources regarding federal acquisition.
A vendor or contractor might register with SAM by providing procurement information and financial transactions in order to obtain awarded contracts from the U.S. government. For the ORCA, other information like travel and accounting policies are included to verify federal requirements. It’s also not uncommon for government agencies to find contractors through SAM.
Implications of Being on the SAM Exclusion List
There are many causes that can lead to the GSA including an entity on the exclusion list. Among those reasons are:
- Fraud, theft, bribery, embezzlement, and other illicit activities
- Unpaid federal taxes exceeding $3,000
- Violations of the Drug-Free Workplace Act
If you find an entity on the EPLS or SAM Exclusion lists, then that individual or organization cannot receive federal contracts. Under federal payment programs, you cannot purchase products from excluded vendors or pay salaries to excluded individuals.
However, you can still follow through with a contract as long as the vendor does not have to be GSA-approved and does not require reimbursement through federal program money. Do your due diligence by consulting with your legal team before proceeding with such a contract.
For more comprehensive information about effective compliance in the healthcare industry, download our white paper or visit our Resource Center.
Get It Done Right with Descartes
Is medical compliance proving to be an expensive endeavor? Are you concerned that you might accidentally miss an exclusion?
If you need help with denied party screening or other aspects of global trade intelligence and compliance, Descartes has solutions for you.
Explore our specialized screening solutions now available to healthcare institutions like hospitals, pharmaceutical companies, and more. Contact us today to learn more about how we can help you achieve GSA compliance.
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