These terms govern C.F.A.I.'s exclusion screening service. By signing up, paying for, or using the service, you ("the Client") agree to them. Please read them — they define what C.F.A.I. does, what you are responsible for, and the limits of that relationship.
C.F.A.I. screens the individuals and entities you submit against publicly available federal and state exclusion, debarment, and sanction lists — including the HHS-OIG LEIE, SAM.gov, OFAC, and available state Medicaid exclusion lists (including California's Medi-Cal Suspended & Ineligible Provider List). C.F.A.I. compiles the results into a dated report and, on an ongoing subscription, re-screens on a recurring basis.
C.F.A.I. provides screening information to help you meet your compliance obligations. C.F.A.I. is a data and screening service — not a law firm, and it does not provide legal advice. A screening report is a tool to inform your decisions. It is not a legal determination, a guarantee of compliance, or an employment decision.
You, the Client, are solely responsible for the information you submit. Specifically, you are responsible for ensuring that the information is:
C.F.A.I. screens the data exactly as it appears in your own submission. C.F.A.I. does not alter, correct, or supplement the identifying information you provide. Screening results reflect only the data you submitted, checked against the lists described above, as of the date the screening is run.
C.F.A.I. retains your submissions and the dated reports it returns. When your roster changes, prior versions are preserved and marked as superseded — C.F.A.I. does not delete or overwrite your submitted data. This creates a dated record of exactly what was submitted, and what was screened, for each cycle. These records are maintained for your benefit and as a record of the service performed.
Because different people and entities can share the same or similar names, screening may return "possible matches" that require review. C.F.A.I. will identify these for you. Confirming or ruling out a possible match, and any decision that follows, is yours. Confirming a possible match may require additional identifying information, which you are responsible for verifying — including, where necessary, directly through official government sources.
All decisions about your own staff and vendors — hiring, retention, leave, contracting, or termination — are made by you and your organization, under your own policies and applicable law. C.F.A.I. provides information; it does not make, direct, or recommend any employment or contracting decision. You remain responsible for your own compliance with all applicable laws and program requirements. C.F.A.I.'s service assists with, but does not replace, your compliance obligations.
Exclusion lists are published and updated by government agencies on their own schedules. There can be a lag between when an agency adds or removes an entry and when it appears in a published list. C.F.A.I. makes commercially reasonable efforts to use current data and to re-screen on the stated schedule, but does not guarantee that any list is complete, error-free, or updated in real time, because the underlying government data is outside C.F.A.I.'s control.
This exclusion screening service does not require, request, or store Social Security numbers. Screening is performed using names, dates of birth, NPIs, and EINs. Where confirming a possible match requires an SSN, the Client verifies that directly through official government resources — keeping your most sensitive data in your own hands. Any future or premium service tier that involves additional identifiers would be offered under its own terms and additional safeguards.
C.F.A.I. provides its service using commercially reasonable efforts. To the maximum extent permitted by law, C.F.A.I.'s total liability for any claim arising out of or relating to the service is limited to the amount you paid C.F.A.I. for the service in the three (3) months preceding the claim. C.F.A.I. is not liable for indirect, incidental, consequential, or punitive damages, for any decision you make based on a screening result, or for any loss arising from information you failed to submit, submitted inaccurately, or failed to keep current.
The service is billed monthly at the agreed rate. There is no setup fee and no long-term contract. You may cancel at any time, effective at the end of the current billing month.
C.F.A.I. may update these terms. Continued use of the service after an update constitutes acceptance of the updated terms.