Updated July 15, 2026
FACIS levels differ by source coverage. Level 1 searches federal sanction sources only, including the OIG LEIE and SAM.gov. Level 1M adds state Medicaid exclusion data. Level 2 adds one specified state’s licensing board records. Level 3 searches sanctioning boards across all 56 U.S. jurisdictions. Most facilities billing Medicare or Medicaid should run Level 3 plus monthly exclusion monitoring.
What is FACIS and why do healthcare employers need it?
FACIS (Fraud and Abuse Control Information System) is the healthcare industry’s aggregated database of sanctions, exclusions, debarments, and disciplinary actions taken against individuals and entities, maintained by Verisys. It exists because a standard criminal background check will not tell you whether a nurse, physician, billing manager, or vendor has been excluded from federal healthcare programs.
That gap has a price. Employing or contracting with an individual excluded by the HHS Office of Inspector General exposes the organization to civil monetary penalties and denial of payment for items or services furnished by that person, under the OIG’s exclusion authorities (OIG Exclusions Program). The OIG’s 2013 Special Advisory Bulletin on the effect of exclusion makes clear that liability can attach even when the excluded person does not treat patients directly, if their work contributes to federally reimbursed items or services (OIG SAB, May 8, 2013).
FACIS is how employers search that exposure across thousands of sanctioning sources in one query, alongside standard screening like a national criminal database search.
What does each FACIS level actually cover?
Composition per Verisys’s own definitions (Verisys FAQ):
| Level 1 | Level 1M | Level 2 | Level 3 | |
|---|---|---|---|---|
| OIG LEIE (List of Excluded Individuals/Entities) | Yes | Yes | Yes | Yes |
| SAM.gov / GSA exclusions | Yes | Yes | Yes | Yes |
| Other federal sources (DEA, FDA, PHS, ORI, TRICARE, OFAC-SDN, Medicare Opt-Out) | Yes | Yes | Yes | Yes |
| State Medicaid sanctions and state procurement/contractor debarments | No | Yes | Yes | Yes |
| State licensing and disciplinary board actions | No | No | One specified state | Sanctioning boards from all 56 U.S. jurisdictions, all provider types |
| Typical use | Minimum federal exclusion check | Exclusion compliance baseline for Medicare/Medicaid billers | Single state license discipline focus | Enterprise standard, credentialing, gold standard search |
Verisys describes Level 3 as the gold standard of sanction and exclusionary searches, drawing on more than 3,500 primary sources, including some 2,500 state sources (Verisys). Exact source counts change as boards are added; treat published totals as approximate.
Which FACIS level does my facility need?
Run Level 1 or 1M if you are a non-clinical employer with incidental healthcare exposure, or you need a fast federal exclusion check on vendors. If you bill Medicare or Medicaid at all, 1M is the realistic floor: CMS has directed state Medicaid programs to have providers screen employees and contractors against state exclusion sources, not just the federal LEIE (CMS State Medicaid Director letter SMD 09-001, Jan 16, 2009).
Run Level 2 if your compliance concern is concentrated in a single state: for example, a single state staffing agency that wants licensing board discipline (suspensions, probations, reprimands) that has not yet escalated to a federal exclusion. Board actions are the early warning; exclusions are the lagging indicator.
Run Level 3 if you are a hospital, health system, SNF, home health, hospice, lab, telehealth group, or multi-state staffing agency, or you credential providers. Clinicians are licensed and disciplined across state lines, and a Level 2 search in your state misses the revoked license in the state next door. Level 3 is the accepted standard for credentialing grade due diligence and is what most acquirers, payers, and accreditation surveyors expect to see.
The practical rule: if the person will touch patients, records, prescriptions, or claims that are federally reimbursed, screen at Level 3 at hire.
Why does monthly OIG re-screening matter more than the level you pick?
The OIG updates the LEIE monthly, and state Medicaid agencies add exclusions continuously. A clean FACIS result at hire proves nothing about month seven. CMS guidance directs state Medicaid programs to require monthly screening of employees and contractors against exclusion sources (SMD 09-001), and the OIG’s 2013 Special Advisory Bulletin identifies monthly LEIE checks as the way to minimize civil monetary penalty exposure (OIG SAB, May 8, 2013).
Penalty math makes the case: civil monetary penalties can apply per item or service furnished by an excluded person, plus repayment of associated claims. One missed exclusion on a full time clinician can dwarf a decade of screening costs.
Reveal pairs a point of hire FACIS search with ongoing monthly exclusion monitoring, so a new sanction on a current employee generates an alert instead of an OIG demand letter. See our healthcare compliance check and the FACIS Level 3 search.
How does FACIS fit into a complete healthcare background check?
FACIS covers sanctions and exclusions only. It is not a criminal history search, and exclusion screening alone does not satisfy state healthcare employment screening laws. A complete healthcare package typically includes:
- FACIS Level 3 plus monthly monitoring
- County and national criminal searches
- Nationwide sex offender registry
- SSN based identity and address history search
- License verification and, for driving roles, an MVR
See the full overview at healthcare background checks.
FAQ
What is the difference between FACIS and the OIG LEIE? The LEIE is one source: the OIG’s own exclusion list. FACIS is an aggregation of the LEIE plus SAM.gov, other federal sanction sources, state Medicaid exclusion lists, and state licensing board actions. Searching the LEIE alone misses state level exclusions and board discipline entirely.
Is FACIS Level 3 required by law? No statute names FACIS or its levels. What the law creates is liability for employing excluded individuals (OIG civil monetary penalty authority) and, via CMS guidance to state Medicaid programs, an expectation of monthly screening against federal and state exclusion sources. Level 3 plus monthly monitoring is the industry standard way to meet that expectation with evidence.
How fast does a FACIS search come back? FACIS is a database search, so results typically return same day. Potential matches are verified against primary sources before reporting, which can add time on hit records, consistent with FCRA accuracy obligations.
Does FACIS include nurse aides and non-licensed staff? Yes for exclusions: the LEIE and state exclusion lists include non-licensed individuals, and OIG guidance applies to anyone whose work contributes to federally reimbursed services, including billing, administrative, and IT staff. Licensing board data applies only to licensed professions.
What happens if a FACIS search returns a hit on a current employee? First verify the match against the primary source, then determine whether the action is an exclusion (immediate payment and employment implications for federal program work) or a board action short of exclusion (a review and monitor situation). If the person is excluded, OIG guidance points to removing them from any role tied to federal healthcare program business and assessing self disclosure. Reveal’s verified reporting tells you which situation you are in.
Should we screen vendors and contractors with FACIS too? Yes. OIG civil monetary penalty exposure extends to items or services furnished by excluded contractors and vendors, not just W-2 employees. Most compliance programs screen contracted clinicians, billing companies, and staffing agency personnel at the same level as employees.
Ready for credentialing grade exclusion screening?
Reveal runs FACIS at the level your risk actually requires, verifies every hit against the primary source, and puts your whole roster on monthly exclusion monitoring. Request FACIS pricing
This is general information, not legal advice. Consult your attorney or compliance counsel about your specific situation.
Sources:
- Verisys, FACIS overview and FAQ: https://verisys.com/solutions/facis/, https://verisys.com/blog/what-is-facis/, https://verisys.com/faq/
- HHS OIG Exclusions Program: https://oig.hhs.gov/exclusions/
- HHS OIG, Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (May 8, 2013): https://oig.hhs.gov/exclusions/files/sab-05092013.pdf
- CMS, State Medicaid Director Letter SMD 09-001 (Jan 16, 2009): https://downloads.cms.gov/cmsgov/archived-downloads/SMDL/downloads/SMD011609.pdf
Frequently asked questions
What does FACIS actually search?
Fraud and Abuse Control Information System data: federal and state healthcare sanctions, exclusions, debarments and disciplinary actions, including the OIG exclusion list and SAM.gov.
Which FACIS level do hospitals usually need?
Most hospitals and health systems screen at Level 3, which adds state licensing board actions across all states. Level 1M is the common minimum for meeting OIG guidance.
How often should FACIS screening run?
OIG guidance points to monthly exclusion checking for current staff, not just at hire. Continuous monitoring is how most compliance teams meet that. It is part of our healthcare background checks.
Is FACIS enough on its own?
No. It covers sanctions, not criminal history, identity or employment verification, so it runs alongside a full background check. Package options are on our pricing page.
