In healthcare facilities, it is common to see them seek external help to ease employees' workloads or provide extra hands. However, have you ever thought about whether these external helping individuals need sanction checks or not? The healthcare facilities accepted these external individuals as volunteers, interns, or medical students for a summer rotation. These individuals work for healthcare organizations on an unpaid basis, but does that mean they don’t need screening? The facilities ignore the screening, considering them as a low risk because they aren’t on the payroll. Making a bigger mistake can cause reputational damage and significant fines for the organization.

The Office of Inspector General (OIG) doesn’t care about the W-2 employee. They care about access to healthcare services and their influence. That’s why sanction checks are essential, even for volunteers or interns, because they work around patients and use the medical facilities. Risk can come from any small neglect, it doesn't discriminate based on paycheck. Therefore, take this guide as an eye-opening note and start screening for short-term help employees who are in any way related to medical organizations.

Myth vs. Reality: The Regulatory Gray Area For Unpaid Individuals

Unpaid staff provide help, while hospital facilities provide learning to them. In exchange, they provide the service. There is no monetary exchange settled between them. However, the OIG check, under the Civil Monetary Penalties Law (CMPL), is required to filter out prohibited entities. Employing or contracting with excluded individuals for the provision of items or services paid by the Federal health care program is subject to a fine. The term "contracting with" is used to include all minor, short-term individuals who contributed to the organisation. 

People often get confused, whether due to a lack of knowledge or ignorance. Most of the time, it’s a myth that binds their minds, and they can’t follow the simple OIG screening process. Here is the table that busts these myths. Read and understand them carefully so that next time you are prepared to take the right action based on facts and rules. Without following some myths in the tactical critical process.

Accessing the Risk Level of Unpaid Roles Under Organization

OIG screening is essential because not all volunteer or unpaid roles pose the same risk for fines or reputational damage. A volunteer playing the piano in the lobby is different from a volunteer filling patients' records or supplying materials to wards.  Let’s review each role within the job hierarchy and identify the risks it introduces when it’s not screened. 

1. High Risk: Medical Residents & Students

Medical residents and students pose the greatest risk to the organization, as they assist doctors in treating patients. Furthermore, they pose a threat due to their significant access to sensitive systems and patient records. These residents and systems have EMR (Electronic Medical Record) access and direct patient contact, which means they can access patients' health information. Treat them exactly like employees. Run a standard OIG Check on them before entry and monthly thereafter. 

2. Medium Risk: Administrative Interns

Administrative Intern handles billing data, enters patient records, and makes reports on health conditions. Furthermore, they work on vendor contracts or patient intake forms. Therefore, they have almost all the information about the patient and the vendor you are contacting. If an excluded entity gains access and steals information, it can be highly damaging to the organization, and patients may be at risk. Mandatory screening is required before granting access and before work begins.

3. Low Risk: General Volunteers or Shop Owners

The list includes small-shop vendors in the waiting area, gift-shop workers, and lobby greeters. The risk here is very low. However, the best practice is to maintain the baseline of security and ensure reputational safety. So do not forget to screen them as well.

4. Board Members (Unpaid)

Board members are crucial to organizations. They make policies, approve budgets, and oversee leadership. Meaning they hold significant power to shape the organization. They are fiduciaries, so ensure they undergo OIG screening without fail. Because even when they do not get paid, they run the whole organization themselves.

Best Practices for Continuous Screening of Neglected Workforce

Effective continuous management of this unpaid list of individuals is vital for safety and reputational assurance. You can strategically plan and divide the work to avoid overwhelming the HR department and get the work underway. These individuals often skip frequent checks because they are not in the HRIS payroll system. Allowing them to slip through the cracks in automated monthly monitoring. A few actionable steps include the following:

• Centralize Data: Create a “Non-Employee” roster in your compliance software and store all information for these individuals.

• The onboarding Gate: Ensure not to issue any badges or allow any access to any sheet or information without a clear screen.

• The School Liaison Protocol: Meaning to form an agreement between the university and the partnering organization. It’s a legal compliance document for data sharing between hospitals and the university. When students rotate across multiple organizations to complete their studies and practice, there may be gaps in oversight or accountability without a clear agreement.

As you proceed, translate these actions and strategies into concrete steps. Here are the 4 steps to secure the volunteer programs effectively.

1. Update Your Policy: Specifically mention and state that volunteers are subjected to background and exclusion checks. 

2. Automate the Frequency: Automate the check for them as well. Do not rely on a manual spreadsheet. Ensure that the sanction checks are done for volunteer matches employees (monthly).

3. Audit the Roaster: Volunteers often leave without notice, and their information keeps sitting in the data. Every quarter, please ensure the data is cleaned up.

4. Document the Evidence: With every check, document the subject, keep the evidence that timely checks have been ensured, and that they have not been neglected.

Final Words!

The compliance check focuses on maintaining the integrity of the healthcare environment, not just on the employment contract. Performing timely sanction checks isn’t just about avoiding fines. It’s about patient safety and trust. Furthermore, it reflects your best interests, good intentions, and determination in your work. If you’re not checking in with volunteers, interns, and unpaid board mentors. This is your reminder to review the roster and correct any missed items. To ensure the checks are not missed and do not become hectic, switch to automated tools like Venops. With automation, the work gets streamlined, and the screening is done accurately.