Illinois Healthcare Worker Criminal Background Check Act

Medicare/Medicaid Anti-Fraud and Abuse Amendments

Provides instruction for compliance with the Medicare-Medicaid Anti-Fraud and Abuse Amendments to the Illinois Health Care Worker Criminal Background Check Act (HCWCBCA) for applicants and continuing employees in the College of Medicine and/or the College of Nursing.

All personnel - academic, civil service staff , or any other classification of personnel appointed in the College of Medicine and/or the College of Nursing at the University of Illinois at Urbana-Champaign, will be screened for any instance of an appearance on any Medicare-Medicaid sanction list or other list where they are found to be required to be excluded from participation in Federal or State Health Care Programs.

Who Must Comply: Both applicants and current employees of the University of Illinois who are or potentially will be appointed in the College of Medicine at Urbana-Champaign and/or the College of Nursing at Urbana-Champaign.

Initial Hiring Procedures: A signed Conditional Hire Acknowledgement form. The form must be submitted to the College of Medicine and/or the College of Nursing Human Resources Office in a timely manner.

The appropriate college human resources office will conduct the sanction check. If the sanction check indicates the applicant, who has been given a conditional offer of employment but has not yet started work, is sanctioned and therefore has been excluded from participation in federal or state healthcare programs, the applicant will be denied appointment in positions in the College of Medicine at Urbana-Champaign and/or the College of Nursing at Urbana-Champaign, unless the applicant can validate that he/she is not the person identified on the sanctions listing.

If the sanction check indicates appearance on the sanctions listing, a conditionally hired employee who has started work will be terminated immediately from the College of Medicine at Urbana-Champaign and/or the College of Nursing at Urbana-Champaign position(s). Termination procedures will be coordinated with the appropriate campus human resources office. The employee may seek to validate his/her identity by contacting the excluding governmental body. The applicant/employee is responsible for all costs associated with the identity validation process.

Annual Review Procedures for Current Employees: All current employees in the above named colleges will undergo a sanction review once every year. The Academic Human Resources Office will conduct the annual review. If the review indicates appearance on any sanctions listing, the employee will be terminated immediately from position(s) in the College of Medicine at Urbana-Champaign and/or the College of Nursing at Urbana-Champaign. Termination procedures will be coordinated with the appropriate campus human resources office. The employee may seek to validate identity by contacting the excluding governmental body. The employee is responsible for all costs associated with the identity validation process.

See also:
Policy IX/C — 44 Security Sensitive Positions: Academic Staff Member
Policy IX/D — 7 Nonacademic Background Investigation Program