# Global | Compliance | Exclusion Screenings Policy & Procedure - Healthcare

## https://glowstick.taskus.com/s/article/Global-Compliance-Exclusion-Screenings-Policy-Procedure-Healthcare

Article Effective date: November 1, 2024

Background

United States federal regulations require that businesses supporting certain federally-funded healthcare benefit programs screen individuals and entities that may provide certain services to ensure that such individuals and entities are not restricted from participating in healthcare business. Federal agencies administer and maintain certain lists of restricted persons and entities (“Exclusions Lists”) that businesses supporting federally-funded healthcare benefit programs must check on a regular recurring basis prior to assigning employees or vendors to provide services and monthly thereafter throughout the term of the service support agreement. While TaskUs is not itself a healthcare business, it supports many clients who provide healthcare benefit support to consumers of federally-funded healthcare benefit programs. Many TaskUs healthcare-related clients are subject to the regulatory requirement to check Exclusions Lists and such requirements may apply to TaskUs as well if our agreement with the client and the scope of services TaskUs has contracted to deliver expressly requires TaskUs to complete Exclusions Lists screening.

Federally funded healthcare benefit programs for which Exclusion Lists checks are required include but are not limited to, Medicare and Medicaid. Requests for how this policy applies to recruitment efforts, programs, contracts, and/or vendors will be sent to Compliance by email to Healthcare.Compliance@TaskUs.com .

Purpose

The purpose of this policy & procedure is to establish the Exclusion List screening requirements for employees and vendors to be assigned to support client campaigns in the scope of this policy. This policy enables  TaskUs to support the client's regulatory compliance obligations. This policy applies to Healthcare-Related Lines of Business where there is a contractual obligation to comply with exclusion lists.

Definitions/Acronyms

Policy

TaskUs conducts all applicable background checks on all prospective employees regardless of their job status (full-time, part-time, or temporary) prior to the performance of work functions. These checks include an Initial Screening of the Office of Inspector General (OIG), General Services Administration (GSA), and Office of Foreign Assets Control (OFAC) databases to verify eligibility for participation in federal health programs in addition to TaskUs’ Global Pre-Employment Policy requirements. Additionally, when hiring or contracting with contract workers or vendors to support the specific verticals or lines of business, this policy applies and TaskUs performs both initial and recurring screenings. Furthermore,

If an individual or entity is already listed on the Exclusion Lists prior to the start date or prior to program assignment the individual or entity is considered an Ineligible Person or Entity and TaskUs will not assign such individual or entity to any Healthcare-Related Line of Business. The individual or entity may be reassigned to support a campaign that is in no way associated with a Healthcare-Related Line of Business or terminated.

If an individual or entity becomes listed on the  Exclusion Lists after the start date ,  the individual or entity must be immediately removed from any assigned Healthcare-Related Line of Business. The individual or entity may be reassigned to support a campaign that is in no way associated with a Healthcare-Related Line of Business, or depending on the needs of the business and other available job opportunities, the employee may be terminated.

TaskUs will perform screenings of Exclusion Lists for Healthcare-Related Lines of Business as required in the Agreement. Any time there is a conflict regarding Exclusion Lists between this policy and the Agreement, the Agreement will prevail. In the event assignment of an individual or an entity is required for delivery of services for support of a Healthcare-Related Line of Business prior to execution of the Agreement, assume that Exclusion List screening is required and request clarification from the TaskUs Healthcare Compliance Team by sending an e-mail to Healthcare.Compliance@TaskUs.com. All requests for how this policy applies to recruitment efforts, programs, contracts, and/or vendors will be sent to the TaskUs Healthcare Compliance team.

[ Procedure Follows]

Procedure

Employee Screening

Initial Screening of TaskUs new-hire employees: When a prospective new employee (candidate) is going through TaskUs’s pre-employment process, the Talent Acquisition Operations personnel (TA Ops) will request the candidate’s written consent via e-signature to conduct a background check which includes searching the Exclusion Lists. Once the candidate's name is submitted to the background check vendor, the vendor will search the Exclusion Lists and generate a report of the results, which will then be submitted directly to Workday If the candidate is not found on the Exclusion List, the pre-employment process can proceed as usual. However, if the candidate is identified on the Exclusion List,  the candidate cannot be assigned to the Healthcare-Related Line of Business. In cases where the candidate's name appears on the Exclusion Lists, but it may be a case of mistaken identity, recruiting should request more information from the vendor for further investigation. TA Ops will compare the candidate's Social Security Number (SSN) or National ID (ID) with the person listed on the Exclusion Lists. If the SSN/IDs do not match, the pre-employment process can continue. However, if the SSN/IDs match, the candidate will not be eligible for employment by TaskUs for support of a Healthcare-Related Line of Business.

Recurring OIG/GSA/OFAC Screening of existing TaskUs employees: Every month, TA Ops executes the screens for existing employees assigned to a Healthcare-Related Line of Business through TaskUs’ vendor who searches the Exclusion Lists for any matches. After conducting the search, the vendor reports to TA Ops the results of the Exclusion Lists screening. If the employee or entity is not on the Exclusion List, there is no further action required, and the employee or entity can continue their employment or service delivery to the applicable Healthcare-Related Line of Business campaign. If the employee is found to be on the Exclusion List, it is crucial to take immediate action. The TA Ops, in collaboration with People Operations, will conduct a thorough investigation into the matter. The employee's supervisor will be contacted promptly to remove them from the Healthcare-Related Line of Business assigned campaign. Additionally, the Compliance Department will work with Client Services to ensure that any necessary contract notifications are sent to the affected client.

Transfer of employee to Healthcare-Related Line of Business : TaskUs will follow the same steps outlined above regarding Initial Screenings and Recurring Screenings for employees transferred from another campaign to a Healthcare-Related Line of Business within the scope of this policy. Initial Screening must be performed prior to assignment to the campaign.

Contract Workers, Vendors, Governing Body Member: TaskUs will follow the same steps outlined above regarding Initial Screenings and Recurring Screenings for employees.

Record Retention Exclusion Lists screening results are held and maintained for 10 years. Talent Acquisition Operations will hold and maintain Exclusion Lists screening results for 10 years including ensuring that any vendors supporting this Policy are notified of TaskUs’ record retention requirement. Any vendor supporting TaskUs under this policy is required to return any background check results and data performed to support this policy. TaskUs will have vendors agree contractually to delete all data from their systems and servers. Upon termination of the agreement, vendors must also return any and all data, documents, and other property belonging to TaskUs.

Exceptions To maintain the highest standards of integrity and compliance in our Healthcare-Related Line of Business, there are no exceptions to the Exclusion Lists screening process for employees, contractors, vendors, or governing board members who are assigned or support these operations. This policy and procedure applies to screening of those individuals and entities exclusively serving the Healthcare-Related Line of Business where a written business agreement exists that includes Exclusion List requirements. Any individual or entity outside of these categories is exempt from this policy. If in doubt regarding the applicability of this policy and procedure to a particular campaign, submit a request for determination to Healthcare.Compliance@TaskUs.com . Written business agreements may determine that records of Exclusion List screening results be maintained for the length of the contract, extending beyond the 10-year record requirement. TaskUs will follow this directive as stated within the written business agreement.

Request for Exclusion List Documentation Requests for documentation that evidences Exclusion List screening completed for certain individuals or groups of individuals assigned to a Healthcare-Related Line of Business will be requested as follows: Email Request to Talent Operations at TAOps@taskus.com

Enforcement Talent Acquisitions Operations will ensure that Exclusion List requirements are completed and available for review and inspection. Talent Acquisition Operations will ensure that all vendors performing Exclusion List requirements understand screening, reporting, and documentation requirements. Violation of this Policy requires immediate resolution and corrective action plans to satisfy and maintain requirements. Report violations immediately to Healthcare.Compliance@TaskUs.com or TaskUs Integrity Line at taskus.allvoices.co .

Policy Applicability Requests for determination, if this policy applies to a specific program, recruitment efforts, contract, and/or vendor, are requested as follows: Email Request to Compliance at Healthcare.Compliance@TaskUs.com

Reference(s)/Related Documents/Appendix TaskUs Global Pre-Employment Requirement Policy ( Policy Link ) Global Personal Data Retention Policy ( Policy Link ) CMS Medicare Managed Care Manual, Chapter 21 CMS Prescription Drug Benefit Manual, Chapter 9 HHS OIG Exclusion List Information ( https://oig.hhs.gov/exclusions/ ) GSA/SAM: EPLS ( https://sam.gov/content/home ) OFAC: ( https://ofac.treasury.gov/ )

Revision History

Policy Details

For full policy details, please see the link below:

### Summary
The purpose of this policy & procedure is to establish the Exclusion List screening requirements for employees and vendors to be assigned to support client campaigns in the scope of this policy. This is intended for global TaskUs employees.



 

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kA0UH00000028BB0AY



 

### Status
Published



 

### VersionNumber
5



 

### RecordTypeName
Policy



 

### LastModifiedDate
2025-03-26



 

### JobLevel
Global



 

### Geo
Global