As ProviderTrust monitors your data, a small portion of your providers may be returned as "unable to determine exclusions." Please read below for more information regarding what an unable to determine exclusion is, why you may receive them, and best practices for reviewing and resolving them.
What is an Unable to Determine? When ProviderTrust has reached the furthest level of verification, due to incomplete data on the exclusion sources sites, we are not able to confirm or deny if your provider is a match to the excluded provider.
But why wouldn’t the exclusion sites have complete identifying information on excluded providers?
Exclusion lists have no standard for how much information they are required to provide when reporting an excluded individual or entities. Many state or older exclusions include minimal information such as just a name, city and job role.
Few exclusion sources include the ability to verify by social security number. The following sources currently allow for SSN Verification their website:
- New York (only last 4 of SSN, full EIN must call state)
ProviderTrust performs advanced verification to come to a definitive determination on these alerts including but not limited to searching address history, public records data, data intelligence and augmentation, working with credit bureau partners, contacting exclusion sources directly, etc. Verifiers are able to solve roughly 99% of all potential matches.
The small number of remaining potential matches are returned to our clients, not with the expectation to solve but review in order to evaluate the potential risk and follow your compliance plan.
What if the Middle Name on the Exclusion Record doesn't match the name of my employee?
Middle name isn’t a reliable enough data point to make a highly confident determination on. Many exclusion matches we report, the provider has a mismatching middle name to the exclusion record.
The reason being is that middle names get switched around a lot of times when a women bumps her maiden name up to middle name and drops her middle name, a person can have multiple middle names but only one is reported. There are other instances where middle names can get a bit switched around.
We avoid marking something as a match or no match when we have a mismatching first or last name. We only like to call something a match when it matches on a unique identifier such as the social security number, date of birth or, NPI and only call something a no match when a record doesn’t match on a unique identifier.
So, what should I do when I receive an Unable to Determine alert?
This will depend completely on your company's internal compliance plan and legal advisors. But, ProviderTrust can help! Many of our clients choose to utilize our Sample Affidavit (download a copy link below) and upload it into the provider in question's Passport profile. Completing and uploading an affidavit can serve as proof that your organization has gone through the steps of ruling out a potential exclusion match. Please note: ProviderTrust will not utilize the information provided in the affidavit in any way. It is simply for your records.
If you opt the affidavit, you can upload the affidavit directly into Passport to maintain for your records. Refer to the following article for step by step instructions: How to Upload Supporting Monitoring Documents
We also recommend referring to our blog posts for additional guidance on your compliance plan available: