If you want the short answer on OIG exclusion screening: check every month. The HHS Office of Inspector General refreshes its exclusion list monthly, and the agency’s own guidance says that screening employees and contractors each month is what best limits a practice’s exposure to overpayment and penalty liability. OIG exclusion screening is not a once-at-hire task, and it is not only about clinicians.
An exclusion means the government will not pay for any item or service that person furnishes, orders or prescribes. That bar reaches administrative and management work too, even when that work is never billed as a separate line. So the receptionist who posts charges, the outside coder, the agency nurse covering a shift and the practice manager all sit inside the rule. If an excluded person touches work that federal program money pays for, the practice is the one holding the liability.
This guide covers who to check, which lists to check them against, how often, and what to do on the day you find a name that matches. It is the operational companion to our guide to building a medical practice compliance program, where exclusion checking is one of the seven elements rather than the whole job.
What does an OIG exclusion actually stop you doing?
OIG keeps a public register called the List of Excluded Individuals and Entities, usually shortened to the LEIE. A person or company lands on it after a conviction, a license action, a default on health education loans, or one of the other authorities Congress wrote into the statute. Once they are on it, federal health care programs can pay nothing for items or services they furnish, order or prescribe.
Two details catch practices out, and both come straight from OIG’s updated Special Advisory Bulletin on the effect of exclusion.
The first is the reach into non-clinical roles. OIG states plainly that excluded people may not furnish administrative and management services that federal programs pay for, and that the prohibition holds even where those services are not separately billable. A practice that screens only the people with a license number has screened the smaller half of its risk.
The second is where the liability lands. OIG’s position is that the provider carries the overpayment exposure regardless of who did the screening and regardless of the person’s employment status, whether they are an employee, a subcontractor, an employee of a contractor, or a volunteer. Outsourcing the check does not outsource the consequence. That is worth reading twice before you assume your billing vendor or staffing agency has this covered.
Anyone who hires a person on the LEIE can face civil monetary penalties on top of repaying what the programs paid. We are deliberately not quoting a dollar figure here, because the statutory amounts are adjusted for inflation and any number we print will be stale before the year is out. Check the current figure against the regulation rather than against an article.
How often should you run OIG exclusion screening?
The consensus answer across compliance guidance is monthly, and the reasoning is mechanical rather than cautious. OIG posts supplemental exclusion and reinstatement files every month. A quarterly or annual cadence means a practice can carry an excluded person for weeks or months while the government’s own record already shows the problem, and the overpayment meter runs the whole time. For state Medicaid agencies OIG is firmer still: the LEIE is to be checked monthly and at any new enrollment.
Here is the part the consensus answer leaves out, and it is the pattern we see most often in practice. The monthly cadence is rarely the thing that fails. What fails is the roster. A practice sets up a monthly check, points it at the payroll export, and never adds the contractors, the per diem coverage, the transcription vendor or the two people the practice manager onboarded in March. The calendar reminder fires faithfully every month against an incomplete list, and everybody feels covered.
Our own search data points the same way. Across the 1,225 queries that brought practices to this site between 26 June and 22 September 2026, compliance-program searches show up steadily, and searches about exclusion checking, the LEIE or SAM registration do not appear at all. Practice managers are looking for the program. They are not looking for the one recurring task inside it that carries direct financial exposure. That gap is the reason this page exists.
Who belongs on the screening roster?
Build the roster from the question “does federal program money pay for any part of what this person does for us?” rather than from the payroll system. In a typical independent practice that pulls in:
- Every employee, clinical and administrative, including front desk, scheduling and management
- Locum and per diem clinicians, and nurses supplied by a staffing agency
- Billing and coding contractors, whether individuals or firms
- Physician groups you contract with for coverage
- Vendors whose people work inside your workflow, such as transcription or scribes
- Volunteers and unpaid students who touch patient care or claims
OIG specifically names staffing agency nurses, contracted physician groups providing coverage, and billing or coding contractors as categories worth screening. Entities go on the list as well as people, so check the vendor’s company name and tax identification number, not only the individual you deal with.
Hiring is the natural place to catch this the first time. If you are rebuilding your physician onboarding process or your employee handbook, put the pre-hire check and the monthly recheck in writing there, so the obligation survives a change of office manager.
Which lists do you actually search?
Three, and they are not interchangeable.
The LEIE is the primary source, searchable free at the online searchable exclusions database. OIG recommends practices treat it as the main record for OIG exclusions because OIG maintains it, updates it monthly, and carries more detail about excluded people than the alternative.
SAM.gov, the federal System for Award Management, carries government-wide debarments and exclusions from every agency, not only OIG actions. It catches names the LEIE does not, which is why serious programs search both rather than choosing one.
Your state Medicaid exclusion list. Most states publish their own, and a state termination does not always appear in the federal registers. If you bill Medicaid in more than one state, that is one list per state, and this is where an otherwise tidy monthly routine most often has a hole.
Free searching is realistic for a small practice. A ten-person office checking three registers is an hour of somebody’s month. Paid screening services are a convenience purchase rather than a compliance requirement, and buying one changes nothing about where the liability sits.
What do you do when a name matches?
Slow down before you act. Common names produce matches constantly, and firing somebody over a coincidence is its own kind of problem.
First, verify identity. The online searchable LEIE lets you confirm a match using a social security number or employer identification number, and that verification step is the difference between a hit and a real finding. Print or save the verification result, because the evidence that you checked is as important as the check.
If the match is genuine, stop that person’s involvement in anything federal program money pays for, immediately. Then work out the exposure: how long were they in the role, and what did the practice bill during that period that their work touched? That question is a records exercise, and a structured coding and documentation audit is usually the cleanest way to put a number on it.
Where the practice has real penalty exposure, OIG operates a Provider Self-Disclosure Protocol for exactly this situation, and using it is generally treated better than waiting to be found. This is the point to involve health care counsel rather than to work it out in a staff meeting. The same judgement applies to the wider fraud and abuse rules covered in our Stark Law and Anti-Kickback guide.
Turning it into a routine that survives staff turnover
A check that depends on one person remembering is not a control. Five things make it durable.
- Name an owner and a backup. One named role runs the check, and a second role runs it when the first is away.
- Keep the roster in one place. Employees, contractors, vendors and volunteers on a single list, updated when anyone joins or leaves, not rebuilt from memory each month.
- Fix the date. The same working day every month, after OIG posts the monthly file.
- Keep the evidence. Date, who was searched, which registers, the result, and the verification output for any match. Evidence you cannot produce is a check you cannot prove you ran.
- Close the front door. No start date before the pre-hire search clears, and a contract clause requiring vendors to screen their own people and to tell you when something changes.
That last point is the one practices thank themselves for later. The vendor clause does not move the liability, but it does give you a contractual route to the information and a reason for the vendor to keep their own house in order.
Exclusion checking also sits next to the credentialing work most practices already do. If you maintain a physician credentialing checklist, the monthly search belongs in the same calendar and often with the same owner, because both run on a roster of people and both fail the same way when the roster is stale.
Common questions
Is monthly checking a legal requirement or a recommendation?
For most private practices it is guidance rather than a statute with a stated frequency. The obligation that is hard is the payment bar itself, and the penalty exposure that follows from employing an excluded person. Monthly is the cadence OIG says best limits that exposure, and it is the cadence OIG requires of state Medicaid agencies, which is why it has become the working standard.
Do we have to check people who never see a patient?
Yes. The payment bar covers administrative and management services as well as clinical care, and it applies even where the work is not separately billable. Scheduling, billing, management and front desk roles all belong on the roster.
Our billing company says they screen their own staff. Is that enough?
It is useful and it is not sufficient. OIG’s stated position is that the provider carries the overpayment liability regardless of who performed the screening and regardless of the worker’s employment status. Ask for their evidence, put the requirement in the contract, and keep the vendor on your own roster.
Is the LEIE the same as SAM.gov?
No. The LEIE holds OIG’s own exclusion actions and carries more detail about them. SAM.gov holds government-wide exclusions and debarments from across federal agencies. A complete search uses both, plus your state Medicaid list.
How long does an exclusion last?
It varies with the authority behind it, and it does not end automatically. An excluded person has to apply to OIG for reinstatement and be granted it. Until that happens the payment bar stands, which is another reason the monthly recheck matters for people already on your roster.
Where practices usually want help
Most independent practices do not need somebody to run their monthly search. They need the roster built correctly once, the evidence trail defined, and the obligation written into hiring and vendor contracts so it does not quietly lapse. That is a short piece of work, and it is the kind of operational detail our principals have had to get right inside a clinic our founder operates, not only in a policy document.
Practice Management Consultancy advises independent practices on compliance program design, credentialing and payer contracting. If you want a second pair of eyes on how your practice handles exclusion checking, or on the compliance program it sits inside, get in touch through our contact page or email contact@practicemanagementconsultancy.com and we will set up a 30 minute call.
This article is general information about practice operations and compliance administration. It is not legal advice. Where a real exclusion is identified, involve health care counsel.
