FACTS™ (Fraud and Abuse Control Tracking System) Description 

SafeGuard acquires, aggregates, links and publishes sanctions and disciplinary actions through our flagship system, FACTS (Fraud and Abuse Control Tracking System). “Sanctions” includes any type of official conviction, debarment, decree, denial, disciplinary action, disqualification, exclusion, expulsion, hindrance, order, penalty, probation, reprimand, sanction, suspension, termination or any type of adverse action taken against a certificate holder, registrant or license/licensee.

FACTS includes Federal (OIG, GSA, DEA, FDA, ORI, PHS, Tricare) plus full taxonomy by state/district/ commonwealth/territory against all boards, agencies or regulatory entities that issue certificates, registrations or licenses (i.e. approximately 830, considerably more than just MDs and DOs alone) to practice or deliver health care goods or services (i.e. persons, professionals, and entities).

FACTS data sets described on three levels:

1. Level 1 is federal sources only,

2. Level 2 is federal plus one state and

3. Level 3 is federal and all jurisdictions.

Specifically for your stated interests, FACTS content includes data from the following primary sources:

• DEA, Office of Diversion Control, Criminal and Administrative Cases Against Doctors

• DEA, Office of Diversion Control, Registrant Actions

• Food and Drug Administration – Warning Letters

• Food and Drug Administration – Debarment List

• Food and Drug Administration – Disqualified/Restricted/Restrictions/Removed/Assurances Lists for Clinical Investigators
  TRICARE Sanctions

• U.S. Department of Commerce, Bureau of Industry and Security, Denied Persons List

• U.S. Department of Commerce, Bureau of Industry and Security, Entity List, Supplement No. 4 to part 744 of the Export Administration Regulations

• U.S. Department of Commerce, Bureau of Industry and Security, Export Administration Regulations, General Order 3 to Part 736

• U.S. Department of Commerce, Bureau of Industry and Security, Unverified List

• U.S. Department of Health and Human Services, Office of the Inspector General (OIG) List of Individuals/Entities Excluded from Federal Health and Medicare Programs

• U.S. Department of Health and Human Services, Office of Research Integrity, PHS Administrative Actions

• U.S. Department of State, Directorate of Defense Trade Controls, Statutorily Debarred Parties

• U.S. Department of Treasury, Office of Foreign Asset Control, Specially Designated Nationals

• U.S. General Services Administration (GSA) List of Parties Excluded from Federal Procurement Programs

• U.S. General Services Administration (GSA) List of Parties Excluded from Federal Nonprocurement Programs

• U.S. General Services Administration (GSA) List of Parties Excluded from Federal Reciprocal Programs

Note: Numerous other federal data sources are collected and used. The FBI’s wanted lists are included in addition to the ones listed above as one example. The list is extensive, but often the record count is low and the source data does not have significant depth. However, these additional data may be important to the historical and current view of the provider, employee, or business entity.

FACTS Level 3 adds all state-level sanction information to FACTS Level 1 federal sources above. Why is this important? In August 5, 2008, the Deputy Inspector General for Evaluation and Inspections issued a Memorandum Report to the Director, Medicaid Integrity Program that “About Two-Thirds of Providers With Final Actions Imposed by State Medicaid Agencies In 2004 And 2005 Were Not Found in the (OIG) Exclusions Database.” Without a complete review of available state-level sanctions data (which is uniquely implemented in FACTS Level 3), clients run the risk of missing individuals and entities who are trying to hide their record by hopping states or health professions, changing business names or paper ownership, and/or those attesting they have "never" been sanctioned when in fact they have. Additionally, the historical sanctions data (not saved or available when searching OIG, GSA and other federal sources) improves the potential to anticipate recidivism for those previously sanctioned and/or those linked to criminal actions (county/state) and/or abuse registries (county/state) which are also available from SafeGuard.

This said, FACTS Level 3 includes the following additional data sources:

• State Agency Issued Sanctions, again, “Sanctions” include any type of official conviction, debarment, decree, denial, disciplinary action, disqualification, exclusion, expulsion, hindrance, order, penalty, probation, reprimand, sanction, suspension, termination or any type of adverse action taken against a certificate holder, registrant or license/licensee.

• State Board Issued Sanctions

• State Division Issued Sanctions

• State Department Issued Sanctions

• State [entity] Sanctions, i.e. any other type of state governmental entity with administrative, regulatory or other state powers to oversee a profession or business operation that may issue, restrict or revoke a professional or business license, registration or certificate to engage in the practice of delivering health care related services or goods.

• State Contractor Disqualification Lists

• State Registry

• State Medicaid Exclusions

• Medicare/Medicaid Opt-Out Lists

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