The Tennessee Hospital Association is pleased to provide the THA Sanctions Databank service. This service provides a convenient internet access and database query to the monthly OIG published "Cumulative Sanctions" paper reports at a cost less than if you maintained the database in-house. Those individuals charged with the development and ongoing maintenance of your compliance program efforts will find this service a valuable tool.

Who should use the THA Sanctions Data Bank?

• Compliance Officers
• Human Resources departments
• Medical Staff Credentialing coordinators
• Reimbursement and Billing offices
• Purchasing departments

Why is the review of the Cumulative Sanctions reports so important?

• The Office of Inspector General’s Compliance Program Guidance for Hospitals (February 1998), for Home Health Agencies (August 1998), and for Clinical Laboratories (August 1998) lists one of the compliance officer’s primary responsibilities as the assurance the "Cumulative Sanctions Reports" have been checked with respect to all employees, medical staff and independent contractors.
• Section 4304 of the 1997 Balanced Budget Act specifies the imposition of civil money penalties for a facility that "arranges or contracts (by employment or otherwise) with an individual or entity that the person knows or should know is excluded from participation in a Federal health care program (as defined in section 1128B(f)), for the provision of items or services for which payment may be made under such a program".

THA currently provides a FREE trial period to review the service. Please use this time to have your staff access and evaluate the service free of charge. To obtain the trial period username and password, call Nora Sewell at THA (615) 256-8240 or e-mail.   If you wish to subscribe to the THA Sanctions Data Bank service there is a $300 annual facility subscription fee.

To subscribe please use this order form. Subscription to this service is facility specific, however there may be unlimited users within the facility.

The information provided through the THA Sanctions Data Bank Service neither constitutes legal advice nor creates a fiduciary duty to any subscriber. Each subscriber should consult its own counsel for advice concerning compliance requirements and activities in its particular circumstance. This interaction is not privileged attorney/client communication. THA Sanctions Data Bank information was obtained from the U.S. Department of Health and Human Services, Office of Inspector General and THA has not independently verified the accuracy of the information. Discretion should be used in sharing sensitive or confidential information.