Sanctions Checking Policy
(Healthcare Organization)

Summary

This template provides a form policy and procedure document addressing a healthcare organization's obligation to conduct sanctions (or exclusions) checks of its workforce, as well as those affiliated with the organization, including its agents, contractors, suppliers, and volunteers. It provides standard provisions, terms, and conditions typical to this type of document. This template includes practical guidance and drafting notes. For a full listing of related healthcare compliance content, see Healthcare Fraud and Abuse Compliance Resource Kit. For additional information on the structural elements of compliance programs and building successful healthcare compliance plans, see Compliance Programs for Healthcare Providers, Healthcare Compliance Plan Elements, and Implementing a Healthcare Compliance Plan. For a checklist guiding attorneys through key legal and business questions that healthcare providers should consider when building a compliance program, see Healthcare Compliance Program for Providers Checklist. To compare state and federal healthcare fraud and abuse laws, see the Healthcare State Law Comparison Tool.