Guide · Compliance

How to do OIG, SAM and state exclusion screening

Federal health care programs will not pay for items or services furnished, ordered or prescribed by an excluded person. Screening is how you make sure you are not employing, contracting with or billing for one. Here is a practical process.

Updated · 3 min read · By the Credentik team

Not legal advice. This guide describes common practice and public guidance. Your obligations depend on your state, your provider agreements and your contracts. Talk to a healthcare attorney about your situation, and especially before acting on a confirmed match.

Why screening matters

The HHS Office of Inspector General (OIG) can exclude individuals and entities from federal health care programs. According to the OIG’s Special Advisory Bulletin on the Effect of Exclusion (May 2013), federal health care programs will not pay for items or services furnished, ordered or prescribed by an excluded person, and a provider that employs or contracts with one can face civil monetary penalties and overpayment liability.

States run their own Medicaid exclusion and termination lists as well. A provider terminated by one state’s Medicaid program may not appear on the federal list.

Step 1: Decide who to screen

The OIG bulletin focuses on employees and contractors who furnish, order or prescribe items or services, or who perform administrative and management functions related to them. In practice, many organizations screen:

  • Every provider, whether employed, contracted or credentialed for a client
  • Staff and contractors, including billing and administrative staff
  • Owners, officers and managing employees, where provider agreements ask for it

Step 2: Choose the lists

ListScreenWhere
OIG LEIEEveryoneoig.hhs.gov/exclusions (online search and downloadable file)
SAM.gov exclusionsEveryonesam.gov
State Medicaid listsEach state where the person is licensed, enrolled or practisesOur state-by-state directory
Medicare opt-out listProviders who bill Medicaredata.cms.gov

The OIG recommends the LEIE as the primary database for exclusion screening because it is maintained by the OIG, updated monthly and has more detail about OIG exclusions than SAM.

Step 3: Screen before hire and every month

Screen before a person starts or is credentialed, then re-screen everyone on a schedule. The OIG updates the LEIE monthly and says monthly screening of employees and contractors best minimizes potential overpayment and penalty liability. Federal rules also require state Medicaid agencies to check the LEIE and federal exclusion list no less frequently than monthly (42 CFR 455.436), and in State Medicaid Director Letter #09-001 CMS directed states to require providers to screen their own employees and contractors.

Step 4: Resolve possible matches

A name match is a question, not a finding. Common names produce false positives, and a real exclusion can hide behind a name change.

  • Compare every identifier the list provides: NPI, license number, date of birth, address, provider type.
  • For the LEIE, the online search lets you verify a possible match against the individual’s identifying information.
  • Check whether the exclusion is current or the person has been reinstated.
  • Record who reviewed the match, what they compared and the outcome.

Step 5: Document the results

If you are ever asked to show that screening happened, a record of each run is the evidence. Keep:

  • The date of each screening and the list version or “as of” date
  • Who was screened against which lists
  • Each possible match and how it was resolved, by whom
  • A monthly summary you can share with clients or health plans

Step 6: Act on a confirmed match

Follow your compliance policy and get legal advice. Typical steps include removing the person from furnishing, ordering or prescribing items and services billed to federal programs, reviewing claims that may involve them, and deciding with counsel whether repayment or a self-disclosure is needed. The OIG describes its self-disclosure processes on its website. If you screen on behalf of clients, notify the client promptly, as your agreement requires.

Automating it

Doing this by hand every month for every provider and every client is exactly the kind of work that slips. Credentik screens every provider monthly against the OIG LEIE, SAM.gov and the Medicare opt-out list, plus 19 state Medicaid exclusion lists checked automatically, sends possible matches to your team to confirm or clear, keeps the results on each provider’s record and produces a monthly attestation report. See exclusion screening.

Questions

Frequently asked

Is exclusion screening legally required?
For providers, the OIG says no statute or regulation requires checking the LEIE, but the consequences of employing or contracting with an excluded person, including civil monetary penalties and overpayments, make routine screening the practical standard. State Medicaid agencies are required to check the LEIE and the federal exclusion list monthly (42 CFR 455.436), and many state provider agreements and health plan contracts require providers to screen.
Is SAM.gov the same as the OIG list?
No. The OIG LEIE contains OIG's exclusions. SAM includes OIG's exclusions but also debarments by other federal agencies. The OIG recommends the LEIE as the primary database for exclusion screening, and many organizations check both.
Who counts as excluded for screening purposes?
Anyone on the LEIE, plus anyone on a state Medicaid exclusion or termination list for a program you bill. A state termination may not appear on the LEIE, which is why state lists matter.

Run every client from one calm workspace

Try Credentik free for 14 days with your own providers and clients. No credit card, no sales call.

See plans and pricing · Already have an account? Sign in