What is an Unable to Determine Exclusion?

As VendorProof monitors your data, your vendors' monitoring records may be returned with a yellow alert that we call a "unable to determine" exclusion. Please read below for more information regarding what an unable to determine exclusion is, why you may receive them, and best practices for reviewing and resolving them. 

What is an Unable to Determine? When VendorProof has reached the furthest level of verification, due of incomplete data on the exclusion sources sites or lack of data on your vendor, we are not able to confirm or deny if your vendor is a match to the excluded vendor with the same name.

What do you mean lack of data on my vendor?

AP Data can be messy. We often find that vendor data is not always complete, missing key identifiers such as an address, tax id number or social security number or date of birth. As a result, you may receive an "unable to determine" alert with the status of Insufficient or Inaccurate Client Data. This means that we do not have sufficient data on your vendor to fully complete provide you a definitive determination despite any additional research performed by the verification team.

In those instances, we encourage you to locate additional identifying pieces of data (SSN/TIN, Address, DOB) for your vendor and either upload on your next vendor file or manually key into VendorProof. Once VendorProof receives the additional data. We will re-trigger additional verification to match or update to no match. 

Why wouldn’t the exclusion sites have complete information on excluded individuals and entities?

This part is a bummer. Exclusion lists have no standard for how much information they are required to provide when reporting an excluded individual or entities. Many state or older exclusions include minimal information such as just a name, city and job role. This leaves limited details for us to work with when you have someone named Mary Smith as your vendor but there's also someone excluded by the name Mary Smith as well. 

Only few exclusion sources include the ability to verify by social security number/tax ID number. The following sources currently allow for SSN/TIN Verification their website (this may not be available on all records - especially some older exclusions):
- OIG-LEIE
- SAM
- Texas
- Louisiana
- New York (only last 4 of SSN, full EIN must call state for full social verification)
- Maine

ProviderTrust goes above and beyond what's publicly available at the primary source to perform advanced verification with the goal of a definitive determination on potential matches alerts including but not limited to searching address history, public records data, data intelligence and augmentation, working with credit bureau partners, etc. Our rockstar verifiers are able to solve roughly 99% of all potential matches.

The small number of remaining potential matches are returned to our clients, not with the expectation to solve but review in order to evaluate the potential risk and follow your compliance plan.

What if the Middle Name on the Exclusion Record doesn't match the name of my vendor? 

Middle name isn’t a reliable enough data point to make a highly confident determination on. Many exclusion matches we report, the provider has a mismatching middle name to the exclusion record.

The reason being is that middle names get switched around  a lot of times when a women bumps her maiden name up to middle name and drops her middle name, a person can have multiple middle names but only one is reported. There are other instances where middle names can get a bit switched around.

We avoid marking something as a match or no match when we have a mismatching first or last name. We only like to call something a match when it matches on a unique identifier such as the social security number, date of birth or, NPI and only call something a no match when a record doesn’t match on a unique identifier.

So, what should I do when I receive an Unable to Determine alert?

This will depend completely on your company's internal compliance plan and legal advisors. But, ProviderTrust can help! Many of our clients choose to utilize our Sample Affidavit (download sample below). Completing and storing an affidavit can serve as proof that your organization has gone through the steps of ruling out a potential exclusion match. Please note that ProviderTrust will not utilize the information provided in the affidavit in any way.  

We also recommend referring to our blog posts for additional guidance on your compliance plan available: ProviderTrust Blog