How To: Understand an Unable to Determine Exclusion Alert

Summary:

Receiving an “Unable to Determine” alerts happens when incomplete vendor data or limited exclusion source details prevent definitive verification. These alerts highlight potential matches that cannot be fully confirmed or denied. Contributing factors include missing identifiers (e.g., SSN, TIN, DOB) or minimal data on exclusion lists. Clients are encouraged to provide additional vendor information for re-verification and may use affidavits as documentation of due diligence. ProviderTrust resolves most matches, returning only unresolved cases for client compliance review.

____________________________________________________________________________

As VendorProof monitors your data, your vendors' monitoring records may occasionally return a yellow alert, referred to as an "Unable to Determine" exclusion. Please review the information below to understand what an Unable to Determine exclusion entails, why you might receive such alerts, and best practices for reviewing and resolving them.

What is an Unable to Determine? When VendorProof has conducted the most thorough level of verification, due to incomplete data on exclusion source sites or insufficient information about your vendor, we are unable to confirm or deny whether your vendor matches an excluded vendor with the same name.

What do you mean by lack of data on my vendor?

Accounts Payable (AP) data can often be inconsistent. Vendor information is frequently incomplete, missing key identifiers such as an address, tax identification number, social security number, or date of birth. Consequently, you may receive an "Unable to Determine" alert with the status of Insufficient or Inaccurate Client Data. This indicates that, despite additional research by our verification team, we do not have adequate data on your vendor to provide a definitive determination.

In such cases, we encourage you to obtain additional identifying information (e.g., SSN/TIN, address, date of birth) for your vendor and either upload it with your next vendor file submission or enter it manually into VendorProof. Upon receipt of this additional data, VendorProof will initiate further verification to confirm a match or update the status to no match.

Why might exclusion sites lack complete information on excluded individuals and entities?

Exclusion lists do not adhere to a standardized requirement regarding the amount of information provided when reporting excluded individuals or entities. Many state or older exclusion lists include minimal details such as only a name, city, and job role. This limited information presents challenges when, for example, you have a vendor named Mary Smith, and there is also an excluded individual with the same name.

Only a few exclusion sources provide the capability to verify via social security number or tax identification number. The following sources currently allow for SSN/TIN verification on their websites (although this may not be available for all records, particularly older exclusions):
- OIG-LEIE
- SAM
- Texas
- Louisiana
- New York (only the last 4 digits of SSN; full EIN verification requires contacting the state)
- Maine

ProviderTrust goes beyond publicly available information at the primary source to conduct advanced verification aimed at delivering definitive determinations on potential match alerts. This includes, but is not limited to, searching address histories, public records, data intelligence and augmentation, and collaborating with credit bureau partners. Our skilled verifiers resolve approximately 99% of all potential matches.

The small number of remaining potential matches are returned to our clients for review, not with the expectation of resolution, but to enable evaluation of potential risk and adherence to your compliance protocols.

What if the middle name on the exclusion record does not match my vendor’s name?

Middle names are not considered sufficiently reliable data points for making highly confident determinations. In many exclusion matches we report, the provider’s middle name differs from that on the exclusion record.

This discrepancy often occurs because middle names can change frequently; for example, a woman may shift her maiden name to the middle name position and omit her original middle name. Additionally, individuals may have multiple middle names but only one is reported. Other variations and inconsistencies with middle names are also common.

We avoid designating a record as a match or no match based solely on mismatched first or last names. We only confirm a match when unique identifiers such as social security number, date of birth, or NPI align, and we only declare no match when these unique identifiers do not correspond.

What actions should I take upon receiving an Unable to Determine alert?

The appropriate response depends entirely on your organization’s internal compliance policies and legal counsel. However, ProviderTrust can assist you in this process. Many clients choose to utilize our Sample Affidavit (available for download below). Completing and maintaining an affidavit can serve as documented evidence that your organization has undertaken the necessary steps to rule out a potential exclusion match. Please note that ProviderTrust will not use the information provided in the affidavit for any purpose.

We also recommend consulting our blog posts for additional guidance on compliance strategies, available at: ProviderTrust Blog