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Exclusion screening: how often, against what, and what to keep

Employing or contracting with an excluded individual may expose the organization to civil monetary penalties for items or services they furnish that are billed to federal health care programs.

The Ledger · No. 004 · Jul 2026 · Reviewed Sep 30, 2026 · 6 min read

Why it matters

Federal health care programs will not pay for items or services furnished, ordered, or prescribed by an individual or entity excluded by the HHS Office of Inspector General. An organization that employs or contracts with an excluded person can face civil monetary penalties, adjusted annually for inflation, for each item or service that person furnished, plus an assessment and potential exclusion of its own.

Which lists

At minimum, the OIG List of Excluded Individuals and Entities (LEIE). Many organizations also screen the federal System for Award Management (SAM) and the Medicaid exclusion lists maintained by each state in which they operate, since state Medicaid programs apply their own exclusions.

Screening across three sources

No single list is complete. State lists can include actions not yet reflected federally.

SourceWhat it coversCommon cadence
OIG LEIEIndividuals and entities excluded from federal health care programs.At hire and monthly
SAM.govFederal debarments and suspensions, including non-health-care actions.At hire and monthly
State Medicaid exclusion listsState-level exclusions, one list per state you operate in.At hire and monthly, per state

How often

OIG’s Special Advisory Bulletin on the Effect of Exclusion (May 2013) recommends screening before hire and periodically thereafter. Because the LEIE is updated monthly, an employee can be excluded after they are hired, and several state Medicaid programs require monthly checks, monthly screening is the common standard. Screen contractors and vendors on the same cadence where they furnish items or services billed to federal programs.

What to retain

For every screening run: the date, the lists checked, the population screened, and the results. For any potential match: the verification steps taken, the determination, and the action. The retained record is what demonstrates the program worked; a clean result without documentation is difficult to demonstrate.

Closing the loop

Is it working?
Every employee, contractor, and vendor group is screened on the cadence you set, and every potential match is resolved.
Can you show it?
Maintain a screening log with the date, lists checked, population, results, and the resolution of any match.

This article is general information, not legal advice. Regulatory requirements vary by jurisdiction and care setting; confirm specifics against the current regulation and with qualified counsel.

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