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The NBCP is tasked with identifying efficient, effective and economical ways to conduct comprehensive background checks of all prospective direct access employees of long term care (LTC) facilities and providers. Each State awarded a grant under the NBCP is charged with implementing and administering a Statewide program that includes a fingerprint-based State and federal criminal history check and the search of various registries including the required Office of Inspector General’s List of Excluded Individuals and Entities (OIG LEIE).
With the support of technical assistance (TA) through the NBCP, many participating States are using automated processes to conduct the various screenings including a name-based check through the OIG LEIE website.
This check brings back the closest match(es) to the information provided by the user. However, with this search, human intervention is required to review the results and make a determination on whether there is a true match. To further automate the process, CMS and the NBCP TA team looked to the use of the Medicare Exclusion Database (MED), an enhanced version of the OIG LEIE, to complete the search. Commonly called “the MED File,” this CMS system of record is distributed monthly to each State’s Medicaid agency. Unlike the LEIE, the MED File includes Personally Identifiable Information (PII) such as an individual’s Social Security Number (SSN) and date of birth (DOB). Using this file to complete the LEIE search essentially eliminates the need for a manual review as the search would produce an exact match and ultimately make an automatic “CLEAR” or “NOT CLEAR” determination. Automating the match greatly reduces the response time and expenses by significantly decreasing the number of false matches. Additionally, participating States have the ability to do automated registry rechecks monthly of the MED File to search for any new information on individuals currently in their data system, thus providing additional protections for vulnerable populations.
Four NBCP States – Georgia, Ohio, Minnesota and West Virginia – are currently accessing the MED File through their automated background check systems. In the first five months of production, several efficiencies and added protections were noted in using the MED File versus the OIG LEIE manual lookup. The first notable efficiency is automation versus a manual search. When a registry check is initiated, a search of the MED File is automatically completed and a “Clear” or an exact data match is returned within seconds. This response time far exceeds the manual process to click a link accessing the OIG LEIE, typing in the personal identifying information for each applicant and reviewing each returned record to determine if there is a match.
A second evident efficiency is a reduction in the number of false positives avoided by using the SSN-based MED File instead of the name-based OIG LEIE. Since inception of the ARCS system in Ohio, 79,896 applicants have been checked against the MED File with zero matches returned. In comparison, the same applicants were run through a name-based registry search of the OIG LEIE and 186 matches were returned. Thus, using the MED File prevented the timely review of 186 false positive results, saving valuable staff time to confirm the identity of each record.
Because the MED File process is fully automated, States using this process are no longer dependent on remembering to manually upload the monthly updated OIG LEIE file. Recently, a NBCP grantee State using the OIG LEIE had not updated the file in several months. It was later found that a person was previously cleared to work in LTC was in fact on the OIG LEIE and therefore should have been denied employment. With the automatic FileWatch used by the MED File process that situation would have been avoided, again adding another safeguard in ensuring applicants are appropriate to be providing LTC services.
The MED File process is an efficient and effective process that can be replicated in any background screening check program with the appropriate DUA approval.
Active NBCP grantee States interested in accessing the MED File as a part of the background check process should contact their CNA State Liaison or email@example.com.
Graduated NBCP grantee and other States interested in accessing the MED File as a part of the background check process may contact:
- Cheryl Cooper: Cheryl.Cooper@cms.hhs.gov
- Dionna Fair-Latta: Dionna.Fair-Latta@cms.hhs.gov
- Questions and addendum forms for the Data Use Agreement (DUA) Addendum for Data Acquired from the Centers for Medicare & Medicaid Services (CMS) and the Data Use Agreement Update to Existing Data Use Agreement can be submitted to the MED mailbox: MED@cms.hhs.gov