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.
| Source | What it covers | Common cadence |
|---|---|---|
| OIG LEIE | Individuals and entities excluded from federal health care programs. | At hire and monthly |
| SAM.gov | Federal debarments and suspensions, including non-health-care actions. | At hire and monthly |
| State Medicaid exclusion lists | State-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.