{"id":"hosp-09-source-silence","version":"2026-10-06","stamp":"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.","title":"When a source did not answer — handling incomplete screens","org":"Any organization running exclusion, debarment or sanctions screening","owner_role":"Compliance Officer (owner); the screener (execution)","scope":"Every screen where any required source returned an error, timeout, rate limit, format change or was offline; and every source the screening method does not read at all.","frequency":"Per screen; monthly roll-up.","procedure":["Require the screening record to distinguish three states per source: answered with rows; answered with no rows; did not answer. A method that cannot print the third state cannot satisfy this procedure.","A name with any did-not-answer source is 'incomplete', not 'clear'. The month's summary counts it as incomplete until the source is re-read.","Re-read the silent source within ___ business days; attach the second read to the first. If the source stays silent past ___ days, escalate to the Compliance Officer, who records what was done instead (manual lookup at the agency, documented by screenshot with date, or an accepted gap).","Maintain the list of sources the method does not read at all (e.g. SSA Death Master File, CMS Preclusion List, DEA registrant file) and how each is covered by another process or accepted as a gap, with the date the list was last reviewed.","Monthly: report did-not-answer rate per source and maximum days unresolved to the Compliance Committee. A rising rate for one source is a vendor or method conversation, not a reason to relabel it 'no results'."],"not_decided":"Whether to proceed (hire, pay, credential) while a source is silent — the organization's rule, written in the relevant template. This procedure only makes the silence visible and timed.","changes":[["2026-10-06","First issue."]],"standards":[{"standard":"OIG General Compliance Program Guidance — effectiveness of screening; documentation","url":"https://oig.hhs.gov/compliance/general-compliance-program-guidance/"},{"standard":"42 CFR 455.436 — the monthly cadence a missed read breaks","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.436"},{"standard":"Compliance Supplement Part 3 §I — the auditor tests for evidence that the verification occurred","url":"https://www.whitehouse.gov/omb/information-for-agencies/circulars/"}],"measures":[{"measure":"Did-not-answer rate by source","computed_as":"screens where source X did not answer ÷ screens, per source, per month","data_source":"receipt did_not_answer; results CSV","threshold":"set by your protocol; the finding is the number"},{"measure":"Incomplete names at month end","computed_as":"names with an unresolved silent source on the last day of the month","data_source":"roll-up","threshold":"set by your protocol; the finding is the number"},{"measure":"Days to resolve silence","computed_as":"median and max business days from silent read to successful re-read","data_source":"re-read log","threshold":"set by your protocol; the finding is the number"},{"measure":"Not-read list currency","computed_as":"days since the not-read list was last reviewed","data_source":"list header","threshold":"set by your protocol; the finding is the number"}],"records":[{"record":"Per-screen source states","kept_by":"screening system","retention":"per HOSP-08"},{"record":"Re-read log and escalations","kept_by":"Compliance","retention":"per HOSP-08"},{"record":"Not-read source list with coverage notes","kept_by":"Compliance Officer","retention":"current + history"}]}