Healthcare exclusion screening means checking every employee, contractor, vendor, and referring provider against the HHS Office of Inspector General’s List of Excluded Individuals/Entities (LEIE) and the General Services Administration’s SAM.gov exclusions records before hire and on an ongoing basis. An excluded person cannot be paid, directly or indirectly, by a federal health care program, and organizations that bill Medicare, Medicaid, or other federal programs can face civil monetary penalty (CMP) exposure for employing or contracting with someone they knew or should have known was excluded. This is separate from, and a required complement to, a criminal background check and a healthcare sanctions search like FACIS.
What the LEIE actually is
The LEIE is maintained by HHS OIG under the exclusion authority in section 1128 of the Social Security Act. OIG describes it as the list that “provides information to the health care industry, patients and the public regarding individuals and entities currently excluded from participation in Medicare, Medicaid and all other Federal health care programs” (OIG Exclusions FAQ). It is a national database, searchable online or downloadable in full, and OIG updates it monthly, with all exclusion information current by the 10th of every month (LEIE Database and Supplement Downloads).
Exclusions fall into two categories under OIG’s own guidance (Background Information and Exclusion Authorities):
- Mandatory exclusions, required by statute, for convictions tied to Medicare or Medicaid fraud, patient abuse or neglect, felony health care related fraud, theft, or financial misconduct, and unlawful manufacture or distribution of controlled substances. These carry a minimum five year exclusion period, longer for repeat offenses.
- Permissive exclusions, at OIG’s discretion, for grounds such as misdemeanor health care fraud convictions, suspension or revocation of a healthcare license, provision of unnecessary or substandard services, and kickback or false claims conduct.
What exclusion actually blocks
Exclusion is not a symbolic flag. OIG’s guidance states plainly that “no Federal health care program payment may be made for any items or services furnished (1) by an excluded person or (2) at the medical direction or on the prescription of an excluded person” (OIG, The Effect of Exclusion From Participation in Federal Health Care Programs). That prohibition applies no matter how the item or service is billed, including itemized claims, fee schedules, capitated rates, and prospective payment systems, and it applies even when the excluded person’s work is folded into a facility’s overall claims rather than billed separately.
The SAM.gov exclusions list is a different, broader system
SAM.gov exclusions cover the government wide debarment and suspension system, not only health care programs. Under the exclusion types SAM.gov publishes, an agency action can make a person or entity ineligible across federal procurement and nonprocurement transactions: “Agencies shall not solicit offers from, award contracts to renew, place new orders” with an excluded contractor, and “No agency in the Executive Branch shall enter into, renew, or extend primary or lower tier covered transactions” with an excluded participant (SAM.gov, Exclusion Types). A healthcare organization that receives any federal grant, cooperative agreement, or contract, not only Medicare or Medicaid billing, has a reason to check SAM.gov in addition to the LEIE, because the two lists are built for different programs and do not fully overlap.
LEIE vs. SAM vs. a criminal background check vs. FACIS
| Screen | What it checks | Who maintains it | What it does not do |
|---|---|---|---|
| OIG LEIE | Current federal health care program exclusions | HHS Office of Inspector General | Does not show criminal charges, arrests, or license status by itself |
| SAM.gov exclusions | Debarment, suspension, and ineligibility across federal contracts and assistance | General Services Administration | Not health care specific; does not replace LEIE screening |
| Criminal background check | County, state, and federal criminal court records | Courts, reported through a consumer reporting agency | Does not show program exclusions or licensure sanctions |
| FACIS style sanctions search | State licensing board actions, OIG and SAM exclusions, and other healthcare sanctions sources aggregated together | A licensed sanctions database used by consumer reporting agencies | Coverage depends on the source list and update cycle it draws from |
These checks answer different questions, and none of them substitutes for the others. Our FACIS levels explained post walks through how sanctions database tiers differ if you are comparing depth of coverage.
How often OIG says to check
OIG is direct about the fact that there is no fixed federal mandate on screening frequency: “Providers are not required by statute or regulation to check the LEIE… Because there is no statutory or regulatory requirement to check the LEIE, providers may decide how frequently to check the LEIE” (OIG Special Advisory Bulletin, The Effect of Exclusion). Within that same guidance, OIG recommends screening employees and contractors each month, since that cadence best minimizes potential overpayment and CMP liability and matches how often OIG refreshes the LEIE. Many state Medicaid programs go further and require monthly checks as a condition of provider enrollment, so the practical floor for most healthcare employers is a pre hire check plus a recurring monthly re screen, not a one time lookup at onboarding.
What is actually at stake if you skip it
OIG has separate civil monetary penalty authority that reaches organizations, not only the excluded individual. Its own guidance states that a provider “may be subject to CMP liability if the excluded person provides services payable, directly or indirectly, by a Federal health care program” when the provider arranges or contracts with a person it knew or should have known was excluded (OIG, The Effect of Exclusion). OIG’s own enforcement history shows this is actively pursued, with a running series of resolved cases against health care providers for allegedly employing someone they knew or should have known was excluded (OIG, Types of Civil Monetary Penalties and Affirmative Exclusions). Because CMP amounts are adjusted periodically and vary by violation, we are not going to quote a per item dollar figure here. What is consistent across OIG’s own materials is the structure of the exposure: penalties calculated per item or service, additional assessments on top of the penalty, and possible exclusion for the organization itself, layered on top of any Medicaid or Medicare overpayment already owed.
Where exclusion screening fits with everything else you run
Exclusion screening is a records check against government lists. It tells you whether a name and identifier currently appear on the LEIE or SAM.gov exclusions records, and it is only as good as the identifying information used to search it, since common names and data entry differences can create both false matches and missed matches. It is not a substitute for a criminal background check, which searches actual court records at the county, state, and federal level, and it is not a licensure verification by itself. A complete healthcare screening program typically layers exclusion monitoring, criminal history, and license or sanctions verification together, then routes any match to a human for individualized review rather than an automatic decision.
If your organization bills federal health care programs at all, whether as a hospital, a skilled nursing facility, a home health agency, a staffing firm placing clinical workers, or a lab, exclusion screening is worth building as a recurring workflow rather than a one time task. See our healthcare background checks page for how criminal, licensure, and exclusion screening come together for clinical and non clinical roles, and our healthcare compliance check page for how ongoing exclusion monitoring is structured. Our pricing page outlines how these searches are packaged.
A record match is a starting point, not a verdict
Finding a name on the LEIE or SAM.gov exclusions list is information that requires human review, not an automatic disqualification. Confirm identity carefully using date of birth, Social Security number, NPI, or license number before acting, since exclusion databases are searched by name and common names can produce false positives. If a match affects an employment decision and the information came from a background check ordered through a consumer reporting agency, the FCRA adverse action process applies: a pre-adverse action notice, a copy of the report, a copy of the Summary of Rights, and a reasonable waiting period before any final decision. Our FCRA adverse action process post walks through those steps in order.
Frequently asked questions
What is the difference between the OIG LEIE and the SAM.gov exclusions list?
The LEIE, maintained by HHS OIG, covers exclusions from Medicare, Medicaid, and other federal health care programs specifically. SAM.gov exclusions, maintained by GSA, cover the broader government wide debarment and suspension system across federal contracts, subcontracts, grants, and other assistance. A healthcare organization that bills federal health programs and also receives federal grants or contracts has reasons to check both, since the lists are not identical.
Does OIG require monthly LEIE checks by law?
No. OIG’s own guidance states there is no statutory or regulatory requirement to check the LEIE, and providers may decide how often to check it. OIG does recommend monthly screening as the practice that best minimizes potential overpayment and civil monetary penalty liability, since the LEIE itself is updated monthly. Many state Medicaid programs separately require monthly checks as a condition of provider enrollment.
What happens if we accidentally employ someone who is excluded?
Federal health care program payment is not available for items or services that excluded person furnishes, orders, or prescribes, which can create an overpayment obligation on its own. Beyond that, an organization that knew or should have known the person was excluded can face civil monetary penalty exposure. OIG’s guidance describes the exposure as penalties calculated per item or service plus additional assessments, on top of any repayment already owed, so we recommend removing the person from any role touching federal program billing immediately upon confirming a match and consulting counsel on next steps.
Is exclusion screening the same as a criminal background check?
No. Exclusion screening checks government exclusion databases by name and identifiers. A criminal background check searches actual county, state, and federal court records for charges and convictions. They answer different questions and are usually run together for healthcare roles, not as substitutes for each other.
Do we need to screen contractors and vendors, not just employees?
OIG’s guidance addresses employees and contractors together, and the payment prohibition applies to anyone furnishing, ordering, or prescribing items or services paid by a federal health care program, regardless of employment classification. Organizations that bill federal programs generally extend exclusion screening to contracted clinical staff, medical directors, and vendors whose work touches billed services, not only direct employees.
Where do I start if we have never run exclusion screening before?
Begin with a baseline check of your current workforce and active contractors against the LEIE and SAM.gov exclusions records, then build a recurring monthly re screen into your onboarding and compliance calendar going forward. See our healthcare compliance check page for how this is typically structured.
General information, not legal advice
This article explains publicly available OIG and SAM.gov guidance for general information purposes and is not legal advice. Exclusion screening obligations, state Medicaid enrollment requirements, and CMP exposure can vary by program, by state, and by contract, and the rules referenced here change over time. Confirm your organization’s current obligations with your own counsel or compliance officer before building or changing a screening policy.
