Exclusion List Screening: OIG-LEIE and SAM.gov
If your organization bills federal healthcare programs, you have to confirm that no employee, contractor, or vendor sits on a federal exclusion list before they start and on a recurring basis afterward. The two lists that matter most are the OIG’s List of Excluded Individuals and Entities (LEIE) and the exclusions database on SAM.gov. Miss a match, and you can be liable for civil monetary penalties on every claim tied to an excluded person.
What are the OIG-LEIE and SAM.gov exclusion lists?
These are two separate federal registries of people and organizations barred from participating in federal programs. They overlap, but they aren’t the same.
| List | Maintained by | Scope | Update cadence |
|---|---|---|---|
| LEIE | HHS Office of Inspector General | Healthcare program exclusions (Medicare, Medicaid, etc.) | Monthly |
| SAM.gov exclusions | General Services Administration | All federal procurement and non-procurement debarments | Continuously |
The OIG explains that an excluded individual can’t be paid by federal healthcare programs for any items or services they furnish, order, or prescribe. That bar reaches further than people realize: it covers administrative and management roles, not just clinicians. A billing clerk or an IT contractor who touches claims data can trigger liability.
Because the two lists are built for different purposes, screening only one leaves a gap. Most compliance teams check both.
How often should you screen employees?
The OIG recommends monthly screening because the LEIE is republished monthly. Many state Medicaid agencies require it outright, and some maintain their own state exclusion lists on top of the federal ones.
A defensible cadence usually looks like this:
- Pre-hire: screen every candidate before extending an offer
- Monthly: re-screen all active staff, contractors, and vendors against the refreshed LEIE
- On state requirement: check applicable state Medicaid exclusion lists where you operate
- At onboarding for vendors: extend screening to any third party that furnishes billable services
Honest caveat: monthly is the OIG’s recommendation, not a hard federal rule for every entity. Your specific obligation depends on your provider agreements, state Medicaid rules, and contractual terms with payers. Don’t assume a single cadence covers every program you participate in.
What are the penalties for missing a match?
This is where the cost of a sloppy process gets concrete. Under the Civil Monetary Penalties Law, the OIG can assess penalties per item or service furnished by an excluded individual, plus treble damages on amounts claimed. Penalty amounts are adjusted for inflation, so always check the current figures in the OIG’s published guidance rather than relying on an older number.
The pattern of exposure tends to be:
- Per-claim civil monetary penalties for each prohibited item or service
- Treble damages on the amount the program paid
- Repayment of all federal funds tied to the excluded person’s work
- Potential exclusion of the employing entity itself in egregious cases
The damage compounds quietly. An excluded nurse working for six months can taint hundreds of claims before anyone notices, and “we didn’t know” isn’t a defense when the LEIE is free and public.
Who do you actually have to screen?
This is where programs most often come up short — they screen clinicians and stop there. The exclusion reaches anyone whose work contributes to items or services billed to a federal program, which is a much wider net than the people with stethoscopes.
A defensible screening population usually includes:
- All employees, clinical and administrative
- Contractors and temporary staff, including locums and travelers
- Vendors who furnish billable items or services
- Volunteers where they touch billable activity
- Owners, board members, and managers in many program contexts
The safe default is to screen everyone whose work could touch a federal claim, then narrow only where you have a documented reason. Narrowing first and broadening after a finding is how entities end up explaining gaps to an auditor.
How does exclusion screening fit with license verification?
Exclusion screening and license verification answer different questions. One asks “is this person barred from federal programs?” The other asks “is this person’s professional credential valid and in good standing?” You need both.
| Check | Answers | Source |
|---|---|---|
| Exclusion screening | Is the person federally barred? | OIG-LEIE, SAM.gov |
| License verification | Is the credential active and unencumbered? | State licensing boards, Nursys |
| Disciplinary monitoring | Has a board taken action since hire? | State boards |
A clean license doesn’t mean someone isn’t excluded, and a clean exclusion check doesn’t mean their license is current. Teams that treat these as one task tend to miss one of them.
Building a workable screening program
A few practices separate programs that survive an audit from those that scramble:
- Keep dated screenshots or records of every check, including the “no results found” outcomes
- Match on more than name — use date of birth, NPI, or address to resolve common-name false positives
- Document your resolution process for potential matches so a reviewer can follow your reasoning
- Screen the full population, including volunteers, locums, and vendors who furnish billable services
Last updated: June 2026.
The fastest way to make exclusion screening sustainable is to wire it into the same workflow you use for credential checks rather than running it as a separate annual fire drill. Our compliance coverage walks through related employer obligations, and the healthcare compliance guide covers how license and exclusion checks fit together across a clinical workforce. If you want to automate the recurring part, see how the verification API supports scheduled re-screening.