Healthcare organizations should check the OIG List of Excluded Individuals and Entities (LEIE), the federal System for Award Management (SAM), and applicable state Medicaid exclusion lists before hire or contracting and then on an ongoing basis. For most providers, the practical standard is to screen all employees, contractors, vendors involved in federal healthcare program items or services, and ordering or referring professionals at hire and monthly thereafter. OIG, SAM, and state Medicaid lists are related but not identical, and relying on only one list can leave a compliance gap.
Who needs exclusion checks?
Any organization that bills or participates in federal healthcare programs should have an exclusion screening process. That includes physician practices, hospitals, health systems, ambulatory surgery centers, home health agencies, labs, pharmacies, DME suppliers, behavioral health providers, and medical billing companies that support claims tied to federal programs.
The reason is simple: providers may not employ or contract with excluded persons or entities to furnish items or services paid for by a federal healthcare program. The OIG has authority to impose civil monetary penalties on providers that employ or contract with excluded individuals or entities under 42 U.S.C. 1320a-7a and related authorities.
Screening should typically cover:
- Employees, including clinical and non-clinical staff
- Independent contractors and temporary staff
- Vendors that furnish items or services payable by federal healthcare programs
- Referring, ordering, and prescribing professionals where their role affects claims or payment
- Owners, managers, and key personnel, where state rules or payer requirements call for broader review
Even staff who do not directly treat patients can create risk if their work supports federally reimbursable services. OIG guidance has long taken the position that payment may not be made for administrative or management services that are a necessary component of providing items or services payable by federal healthcare programs when those services are furnished by an excluded person.
What is the difference between OIG, SAM, and state Medicaid exclusion checks?
OIG LEIE
The OIG List of Excluded Individuals and Entities (LEIE) is maintained by the U.S. Department of Health and Human Services Office of Inspector General. It identifies individuals and entities excluded from participation in Medicare, Medicaid, and all other federal healthcare programs under section 1128 of the Social Security Act. OIG exclusions are the most healthcare-specific and are central to provider compliance programs.
OIG has expressly advised providers to screen the LEIE regularly and has stated that monthly screening is the best way to minimize potential overpayment and penalty exposure because exclusions are effective when imposed, and reinstatements are not automatic.
SAM
The System for Award Management (SAM), at sam.gov, is the federal government's broader database for procurement and award-related exclusions and debarments. SAM includes parties excluded from receiving federal contracts or certain forms of federal financial assistance. It may also contain healthcare-related exclusions, but it is not a substitute for LEIE screening.
In practice, SAM matters because some healthcare organizations receive federal grants, contracts, or subawards in addition to federal healthcare program revenue. An entity can appear in SAM even if it is not listed in the LEIE, and vice versa. For organizations with federal contracting or grant exposure, SAM screening is an important separate control.
State Medicaid exclusion lists
State Medicaid exclusion or termination lists are maintained by individual state Medicaid agencies or Medicaid Fraud Control Units. These lists can identify persons or entities barred, terminated, suspended, or otherwise ineligible under state Medicaid rules. Some states publish dedicated exclusion databases; others publish termination lists or provider bulletins.
State lists matter because states may act independently of OIG, and a provider can be ineligible under a state's Medicaid program even if not yet reflected on the federal LEIE. In addition, under federal Medicaid rules at 42 CFR 455.436, states must terminate providers terminated by Medicare or another state's Medicaid program, creating a broader network of screening risk.
How often should exclusion checks be performed?
Best practice is to screen before hire or engagement and monthly thereafter. That approach aligns with OIG guidance and is widely treated as the operational standard for healthcare compliance.
OIG's Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs states that monthly screening against the LEIE is the best approach. OIG has explained that screening less frequently increases the risk that claims, administrative costs, or referral-related payments could involve an excluded person during the gap period.
A practical schedule is
- Pre-hire or pre-contract screening before the individual or entity starts work
- Monthly screening of current employees, contractors, and applicable vendors against LEIE, SAM, and relevant state lists
- At credentialing, recredentialing, and ownership changes as an added control, not a replacement for monthly screening
Annual screening alone is generally not sufficient for healthcare organizations participating in federal healthcare programs.
What regulations and guidance support exclusion screening?
Key authorities include:
- Section 1128 of the Social Security Act, which authorizes exclusion from federal healthcare programs
- 42 U.S.C. 1320a-7a, which authorizes civil monetary penalties for employing or contracting with excluded persons in certain circumstances
- OIG Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs, updated in 2013, which explains the scope of exclusion and recommends monthly LEIE screening
- 42 CFR 1001, which addresses OIG exclusion authorities and procedures
- 42 CFR 455.436, requiring state Medicaid agencies to terminate providers terminated by Medicare or another state's Medicaid program
In addition, many organizations build exclusion screening into their compliance programs based on OIG compliance guidance, payer enrollment requirements, and state Medicaid provider agreement terms.
Who exactly should be screened each month?
Organizations should define screening populations based on risk, but a conservative and common approach is to include all workforce members and business relationships tied to federally reimbursable services.
This often includes:
- All employees, regardless of license status
- Locum tenens, agency staff, and volunteers in care settings
- Physicians and advanced practice professionals
- Board members, officers, and owners where required by state or payer rules
- Billing companies, collection vendors, care management vendors, and coding contractors
- Laboratories, transportation providers, DME suppliers, and other downstream vendors involved in patient care or claims support
If a vendor's services are entirely unrelated to federal healthcare program items or services, the risk may be lower. But many organizations still apply broader screening for consistency and auditability.
What should a compliant exclusion screening process include?
Use all relevant sources
At minimum, use the OIG LEIE, SAM, and the state Medicaid exclusion or termination lists for every state where the organization operates, is enrolled, or furnishes services.
Match carefully and resolve potential hits
Name-only matches can produce false positives. Review supporting identifiers such as middle name, date of birth, NPI, address, SSN fragments if lawfully available, and license number. Document how the organization resolved each potential match.
Document every screening cycle
Maintain logs showing who was screened, what databases were used, the date of screening, the search results, and how any matches were investigated. Documentation is critical if auditors ask how the organization verified compliance.
Respond promptly to confirmed matches
If a current employee, contractor, or vendor is confirmed as excluded or terminated, the organization should act immediately. Typical steps include removing the person or entity from duties related to federal healthcare program business, assessing overpayment exposure, consulting legal counsel as appropriate, and considering self-disclosure obligations if claims were submitted.
Common mistakes to avoid
- Checking only the LEIE and ignoring SAM or state lists
- Screening only licensed clinicians instead of all relevant employees and contractors
- Screening annually rather than monthly
- Failing to document search results and match resolution
- Assuming a cleared credentialing file replaces ongoing exclusion checks
- Overlooking vendors whose work supports claims, billing, or patient care
Bottom line
Healthcare organizations that participate in federal healthcare programs should screen for OIG exclusions, SAM exclusions, and applicable state Medicaid exclusions before hire or contracting and monthly thereafter. The lists serve different purposes, and none fully replaces the others. A documented, monthly screening process is the most defensible way to reduce overpayment, penalty, and enrollment risk.