When a source did not answer — handling incomplete screens

Template version 2026-10-06 · for: Any organization running exclusion, debarment or sanctions screening · owner role: Compliance Officer (owner); the screener (execution) · adopted by organization effective date . Editable .txt · JSON

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 General Compliance Program Guidance — effectiveness of screening; documentation — https://oig.hhs.gov/compliance/general-compliance-program-guidance/
42 CFR 455.436 — the monthly cadence a missed read breaks — https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.436
Compliance Supplement Part 3 §I — the auditor tests for evidence that the verification occurred — https://www.whitehouse.gov/omb/information-for-agencies/circulars/

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'.

Findings reported — computed from your own records; the threshold is your protocol's

Finding	Computed as	Data source	Threshold
Did-not-answer rate by source	screens where source X did not answer ÷ screens, per source, per month	receipt did_not_answer; results CSV	your protocol
Incomplete names at month end	names with an unresolved silent source on the last day of the month	roll-up	your protocol
Days to resolve silence	median and max business days from silent read to successful re-read	re-read log	your protocol
Not-read list currency	days since the not-read list was last reviewed	list header	your protocol

Records

Record	Kept by	Retention
Per-screen source states	screening system	per HOSP-08
Re-read log and escalations	Compliance	per HOSP-08
Not-read source list with coverage notes	Compliance Officer	current + history

What this procedure does not decide

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.

Change log

Date	Change
2026-10-06	First issue.
date	adopted / edited by name

Other templates: 01 · 02 · 03 · 05 · 06 · 07 · 08 · 10 · 01 · Duty Sheets (one page per rule, generated on any receipt) · our own procedures · 2026-10-25