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Is it necessary to check for sanctions and exclusions on all employees or just those who work with government programs? And what is the definition of a contractor?

Compliance Monitor, March 5, 2004

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Both the United States Sentencing Guidelines and the Office of Inspector General (OIG) Guidelines state that organizations are responsible for their decisions regarding to whom they give discretionary authority and with whom they do business. 

Their guidelines strongly advise that organizations screen employees and contractors (contractor includes companies/business partners and their personnel, who supply goods and services including management firms and consultants). 

Such screening would ensure that employees and contractors have not been convicted of criminal violations or have not been the subject of sanctions, debarment, exclusion, or other serious adverse action. 

Organizations should develop a specific policy, which reflects screening activities on all employees, and involve at a minimum the following checks:

1. Cumulative Sanction Report - OIG
2. General Services Administration Debarment List
3. National Practitioner Databank (for clinicians)
4. A reasonable prudent background check including a reference check.
5. Requirement that employees disclose any criminal conviction or exclusion action.

Having a policy in place which requires the foregoing checks is instrumental in documenting an effective corporate compliance program.

This question was answered by Norman S. Werner, CHE, associate corporate compliance officer, Westchester Medical Center, Valhalla, NY.

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