LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.03 Employee's Ability to Participate in Federally Funded Health Care Programs
 
  PROCEDURES
  1. Department of Mental Health Human Resources Bureau (DMH-HRB) shall ensure that all new employees sign the Statement of Ability to Provide Services under Federally Funded Health Care Programs form upon hire or interdepartmental transfer, attesting that they are eligible to provide services under a federally funded health care program and have not been:
     
    1. Convicted of a criminal offense related to health care; or
       
    2. Debarred, excluded, or otherwise made ineligible to provide services under federally funded health care programs by a State or federal agency.
       
  2. DMH-HRB shall file the signed attestation form in the employee’s personnel record.
     
  3. DMH-HRB shall complete all required queries of sanction lists prior to completing an action to hire or accept the interdepartmental transfer of a new DMH employee.
     
  4. Clinical Operations shall check licenses for exclusions/suspensions upon certification and re-certification.
     
  5. Compliance, with assistance from Chief Information Office (CIO), shall coordinate with an authorized vendor to complete a monthly sanction screening process against all federal, State and County sanction lists for all DMH employees.
     
  6. Authorized vendor shall notify Compliance about potential matches that arise during the initial screening process.  Designated Compliance staff shall obtain and provide vendor with additional information to resolve false matches and ensure closely matching names found on the sanction lists are not DMH employees.
     
    1. Authorized vendor shall provide Compliance with monthly detailed and summary reports documenting the screening and resolution process.
       
    2. Compliance shall retain reports for 10 years.
       
  7. All confirmed sanctioned individuals shall be subject to immediate follow-up actions to ensure that all billing activities are stopped immediately.
     
    1. Compliance shall immediately notify the responsible Program Manager, Deputy Director, Compliance Officer, and Central Business Office of the excluded and/or suspended finding.
       
    2. Compliance shall notify the CIO and other units as appropriate of a confirmed exclusion and/or suspension to ensure sanctioned individuals cannot submit claims through the DMH claiming system. (DMH Policy 106.09, Removing Names of Sanctioned Individuals from the Rendering Provider List)
       
    3. Upon verification, Compliance will notify the DHCS County Liaison of the excluded provider by the end of the next business day.
  8. If it is determined that a DMH employee is excluded and/or suspended from federal program participation, either through sanction screening results or by direct employee notification, the manager or supervisor, in conjunction with the responsible Deputy Director, shall coordinate the employee’s termination from DMH employment with the DMH-HRB Employee Relations Section.
     
    1. Employees excluded from federally funded health care programs shall be notified of disciplinary action or termination. (DMH Policy 605.01, Discipline; DMH Policy 106.08, Graded Sanctions)
       
    2. Program Managers, in consultation with the responsible Deputy Director, shall carefully coordinate the transfer of duties associated with employees excluded from federally funded health care programs.
       
    3. Executive Staff may, if appropriate given the cause of exclusion, permit a brief period of continued employment for an excluded employee to allow for appropriate transition of direct clinical responsibilities to avoid causing any undue harm to clients.  If this is permitted, the Executive Staff, in association with the Program Manager, shall ensure that no direct service claims or indirect charges are submitted for the excluded employee during the period of continued employment.