Workforce Screening

Approval/Effective Date: 07/22/2009
Last Reviewed: 04/15/2015

Policy: The UW School of Dentistry shall not contract with, employ or extend privileges to any prospective employee, dentist or health professional excluded from participation or otherwise ineligible to participate in federal health care programs.

If an individual whom the School currently employs or credentials becomes excluded from participation in federal health care programs, the School must immediately remove the individual from direct or indirect responsibility for or involvement in any federally funded health care program. The individual may be terminated, consistent with the terms and conditions of employment.

The School will make reasonable inquiry into other criminal offenses of prospective workforce members.

Purpose: The purpose of this policy is to ensure that individuals acting on behalf of the School do not have a history of engaging in illegal or improper activities.

Procedures:

  1. The Office of Medical Staff Appointments verifies the non-excluded status of dentists and other health professionals with medical staff appointments by accessing the National Practitioner Data Bank (NPDB).
  2. Upon employment, School of Dentistry Administrators or their designees verify the non-excluded status of prospective employees by accessing the Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals/Entities on the OIG website (http://oig.hhs.gov/exclusions/index.asp) and the Federal Government’s System for Award Management (SAM) website (https://www.sam.gov/portal/public/SAM/). School Administrators or their designees also verify the non-excluded status of graduate students upon matriculation and on an annual basis by accessing the OIG and SAM websites described above.
  3. The Office of Student Life and Admissions verifies the non-excluded status of all predoctoral dentistry students upon matriculation and on an annual basis by accessing the Department of Health and Human Services Office of Inspector General (OIG) Page 9 List of Excluded Individuals/Entities on the OIG website (http://oig.hhs.gov/exclusions/index.asp) and the Federal Government’s System for Award Management (SAM) website (https://www.sam.gov/portal/public/SAM/).
  4. UW Medicine Human Resources verifies the non-excluded status of all University of Washington employees on a monthly basis by accessing the Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals/Entities on the OIG website (http://oig.hhs.gov/exclusions/index.asp) and the Federal Government’s System for Award Management (SAM) website (https://www.sam.gov/portal/public/SAM/).
  5. Should an employee, dentist or other health professional appear on the OIG List of Excluded Individuals/Entities, the SAM website, or the NPDB, the School may not employ or extend privileges to that individual until the issues are resolved and it is clear that the individual is not excluded from participation in federal health care programs.
  6. Current employees, dentists or other health professionals whose names appear on the OIG List of Excluded Individuals/Entities, the SAM website, or the NPDB will be removed from direct or indirect responsibility for or involvement in any federally funded health care program.
  7. Conviction/criminal history information will be obtained for all prospective employees and faculty, in accordance with Washington State law and University policy.