A Vision Vendor (first tier) for a Sponsor is required to conduct monthly OIG/GSA verifications on all their employees, temporary employees, volunteers, consultants, etc. However, are they required to carry the requirement forward to their contracted providers, i.e., XYZ’s Optical’s entire organization? Should the Vision Vendor conduct audits of their provider network to ensure the provider’s entire staff is being verified through OIG/GSA on a monthly basis?

Yes, the first tier entity is required to carry out the monthly OIG/GSA exclusion
verification requirement to its downstream entities. The sponsor and its FDRs must work
together to develop an effective monitoring strategy to ensure all persons working on the
Medicare program are verified through both listings and none of these persons or entities are
excluded or become excluded from participation in federal programs. Monthly screening is
essential to prevent inappropriate payment to individuals, providers, pharmacies, and entities
that have been added to exclusions lists since the last time the list was checked.