General Service Administration Still Encountering Problems with its System for Awards Management

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Compliance Resource Center identifies data integrity issues in the debarment data maintained in system for awards management and offers best practices for screening the data for healthcare sanctions.

Compliance Resource Center

Nine months after the General Services Administration (GSA) migrated its Excluded Parties List System to the System for Awards Management (SAM), GSA is still working out glitches. The healthcare industry relies on the GSA debarment data to screen its employees, medical staff, contractors and vendors who provide healthcare related services. But as many know, screening the GSA debarment list can be difficult and is not user friendly. To compound matters, GSA recently identified a security breach that resulted in the exposure of GSA registered users’ information. In addition, the Compliance Resource Center, LLC (CRC), made GSA aware of a discrepancy between the searchable exclusion data in SAM and, what should be the same, exclusion data available in a downloadable file.

CRC maintains an online searchable database that incorporates sanction and debarment from federal and state sources, known as S3. While pulling the monthly data extract from the GSA SAM website, CRC’s Database Administrator identified inconsistencies in the exclusion data between what was available online in SAM and what was contained in the data extract available for download from the GSA SAM website.

Upon detecting data integrity problems, CRC’s Database Administrator contacted GSA Federal Service Desk (FSD) on January 31, 2013. The original issue identified was that second and subsequent sanctions imposed on an individual did not contain identifying information in the record. Additional difficulties were identified that caused certain sanctions to be associated with the wrong party in cases where two individuals have the same first and last names, but different middle names, and at least one of the individuals had more than one sanction imposed. Because of the glitch in the data, it was impossible to correctly assign the second and subsequent sanctions to the correct individual. As a result, organizations relying on the data for the purpose of complying with sanction screening requirements do not see complete and accurate data for certain individuals. Many organizations reply, in part, on debarment and sanction data to make hiring and contracting decisions.

In response to CRC’s queries about the discrepancies, the FSD responded via email that it escalated the problem for proper assessment and remediation of the issues. After more than three weeks of CRC’s original request, the FSD reported that the issued has been resolved. However, GSA and FSD never provided an explanation of what caused the problem or how long the glitch was in its system.

Based upon GSA’s notification of problem resolution, CRC’s Database Administrator conducted its own evaluation of the data in order to determine that it is indeed accurate and, therefore, cleared to be used by our clients to conduct screenings. Each data load was, and will continue to be, evaluated by CRC to identify any discrepancies. We determined that the data is complete and are confident that:

•The Database Administrator has verified the data load and the data contained in the downloadable data extract matches the data contained in SAM online.

•The data is being provided such that it is now logically possible to load it correctly.

•Because every row in the data now contains full identity information, we do not have to make assumptions about the rows that contain no identity information.

During this whole period, CRC found the GSA process challenging and created confusion for our clients to accurately verify debarred individuals and/or entities in SAM. In an effort to provide guidance, CRC provides the following suggestions on how to meet the challenge of using the GSA debarment database. Consider the following suggestions to save future headaches:

1. Screen against the GSA SAM only those vendors and contractors providing healthcare related services and/or products.

2. Reduce the frequency of GSA screenings. Monthly screenings can be excessive in cost, time and effort. Consideration may be given to screening individuals and parties at time of engagement and annually thereafter. Alternatively, if GSA screening is something you wish to conduct more frequently than annually, quarterly screening would be preferable and is sufficient.

3. Conduct a “rolling screening” program. This approach is to have continuous screening of a small portion of the universe of contractors and vendors at a rate whereby all have been checked by the end of the twelve month period.

4. Outsource the whole screening process to in order to save time and costs, as well as gain the confidence that the verification and resolution are accurate. Outsourcing grants you the peace of mind that you are meeting the sanction screening requirements and that the screenings are conducted each month, regardless.

You can read more about the GSA debarment data issues by reading the sanction screening advisory bulletin found here.

About the Compliance Resource Center
Compliance Resource Center, LLC provides comprehensive and cost-effective healthcare solution to help organizations manage compliance activities and stay informed with the latest information in a constantly changing environment. CRC is a leading provider for online healthcare compliance solutions, including policies and compliance document templates, sanction screening and verification services, telephone and web-based hotline services, compliance knowledge and effectiveness surveys, and compliance program web-based training. For more information about our solutions visit ComplianceResource.com or contact Jillian Bower at Info@ComplianceResource.com or at 703-683-9600 x405.

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Lynn Topp
WebMechanix
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