When a company initially hires, it is usually pretty good about verifying license information and making the background check –including the exclusion list check.
However, as employees stay with a company, names change, records change, and sometimes licenses change. Therefore, ALWAYS make certain the person who runs the employee’s names through the various databases knows which name(s) to search.
It is better to search additional names than to miss a record. If your company has employed a person whose license renewal lapsed without renewal, or whose exclusion has finally been posted, any work that person performs for which you receive payment creates an overpayment. Resultant overpayments would probably require OIG self-disclosures, and the fall-out from that (the least of which is a penalty).
THEREFORE, make certain you check for a variety of names for any employee who has been married, divorced, etc. FURTHER, do not take for granted renewal dates. Some licenses renewal period for the initial license is shorter than the subsequent renewal periods.
When any employee’s license changes designation, make certain the renewal period is known not only to the licensed provider, but to the agency. Belts and Suspenders is a good idea.
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