Response to a confirmed exclusion, debarment or sanction match
Template version 2026-10-06 — adopted by: ____________________  effective: __________  owner: Compliance Officer (owner); General Counsel (decision partner); HR / MSO / AP / Revenue Cycle (actions)

Template. Written against the public text of the standard cited; the organization adopts, edits and owns it as its protocol. Every threshold, identity, hold or disclosure decision belongs to the organization. We report the findings against the protocol — counts, dates, states — nothing more. Not legal advice, not a compliance determination, not a consumer report.

STANDARDS SERVED
- OIG Special Advisory Bulletin — effect of exclusion; payment prohibition and CMP exposure — https://oig.hhs.gov/exclusions/special-advisory-bulletin-and-other-guidance/the-effect-of-exclusion-from-participation-in-federal-health-care-programs-2013/
- OIG Health Care Fraud Self-Disclosure Protocol (2021) — https://oig.hhs.gov/compliance/self-disclosure-info/health-care-fraud-self-disclosure-protocol/
- 42 CFR 1003 — civil monetary penalties — https://www.ecfr.gov/current/title-42/chapter-V/subchapter-B/part-1003
- 60-day overpayment rule — 42 CFR 401.305 — https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-401/subpart-D/section-401.305

SCOPE
Any roster name whose same-name row has been confirmed as the person or entity by the identity procedure in HOSP-01/02/03.

FREQUENCY
Immediately on confirmation; this procedure is a timed sequence.

PROCEDURE
1. Day 0: Compliance Officer logs the confirmation (who confirmed identity, on what agency fields), preserves the dated record that printed the row and the identity evidence, and notifies General Counsel. Privilege decisions are counsel's.
2. Day 0–1: the role owner (HR / MSO / Supply Chain) takes the interim action the organization's policy prescribes — written here: ___ — and records it. The screening record did not prescribe it; this procedure does.
3. Day 1–10: Revenue Cycle and Finance quantify items or services furnished or ordered by the excluded party during the exclusion period and billed to federal programs; Counsel evaluates the 60-day rule clock and the Self-Disclosure Protocol. Record the analysis and the decision, whichever way it goes.
4. Day 10–30: execute the decisions (refund, disclosure, personnel/contract action); update the roster; record completion dates.
5. Root cause: how did the party get on the roster or stay on it — hiring gap, screening gap, identity gap, source silence? Write the procedural change and its notation in the affected template.
6. Report to the Compliance Committee and Board per the compliance program charter; keep the full file per HOSP-08.

MEASURES (findings reported monthly; the threshold for each is your protocol's)
- Identity-to-counsel time: hours from identity confirmation to counsel notification. Data: response log. Threshold: your protocol: ________
- Interim action time: hours from confirmation to recorded interim action. Data: response log. Threshold: your protocol: ________
- Quantification time: days from confirmation to completed billing analysis. Data: response log. Threshold: your protocol: ________
- Root-cause closure: confirmed matches with a written procedural change and notation ÷ confirmed matches. Data: template change logs. Threshold: your protocol: ________

RECORDS
- Response log (timed steps, decisions, basis) — kept by Compliance Officer — retention per HOSP-08; counsel decides privilege
- Billing analysis — kept by Revenue Cycle / Finance — retention same
- Disclosure/refund correspondence — kept by Counsel — retention same

WHAT THIS PROCEDURE DOES NOT DECIDE
Whether exclusion applies to the services, whether a refund or disclosure is owed, what personnel action to take — counsel and the organization decide. The screening record is evidence of what the file printed and when it was read.

CHANGE LOG (add a line for every change; keep superseded versions)
- 2026-10-06: First issue.
- ________: adopted/edited by ____________________

Source template: https://alphacovenantholdings.com/api/public-record/sop-templates/hosp-07-exclusion-response/html · Duty Sheets: https://alphacovenantholdings.com/api/public-record/duty-sheets · Our own procedures: https://alphacovenantholdings.com/api/trust/sops