OIG Exclusion Check: What It Is and Why Employers Run It
An OIG exclusion check is a search of the HHS Office of Inspector General’s List of Excluded Individuals/Entities (LEIE) to confirm a person is not barred from participating in federal health care programs. If you employ or contract with an excluded person, you risk civil monetary penalties and repayment of claims tied to their work, so most healthcare employers check before hire and monthly after.
What Is an OIG Exclusion?
An OIG exclusion is a sanction that prohibits an individual or entity from billing Medicare, Medicaid, and other federal health programs, directly or indirectly. Mandatory exclusions apply to convictions such as program-related crimes, patient abuse or neglect, and felony health care fraud or controlled substance offenses. Permissive exclusions cover items such as license revocation, and defaulting on health education loans. The OIG maintains the public LEIE database of these individuals.
Who Needs an OIG Exclusion List Search?
Any organization that bills federal health programs should screen, including:
- Hospitals, clinics, and physician practices
- Nursing homes, home health, and hospice agencies
- Staffing firms placing clinical or administrative workers
- Vendors, billing companies, and contractors who touch federally funded services
The exclusion applies to the payment for items or services an excluded person furnishes or directs, including administrative and management roles, not only clinicians.
How to Run an OIG Exclusion Check
1. Collect accurate identifiers
Get the full legal name, prior names, date of birth, and SSN with written FCRA-compliant consent when the search is part of a consumer report. Name-only matches create false positives.
2. Search the LEIE
Use the OIG’s online search by name, and verify any possible match with the SSN or EIN through the OIG’s verification function. Downloadable database files are available for batch comparison of your whole workforce.
3. Check state Medicaid lists and SAM.gov
The LEIE does not cover everything. Many states keep their own Medicaid exclusion lists, and SAM.gov lists federal debarments. Most compliance programs search all three.
4. Document the result
Save a dated record of the search, the identifiers used, and the outcome. Auditors want proof of each monthly check.
5. Act on a confirmed match
Remove the person from federally reimbursed work immediately and consult counsel on repayment and self-disclosure options.
Which Search Fits Which Situation?
| Situation | Recommended check | Timing |
|---|---|---|
| New clinical hire | LEIE, state Medicaid list, SAM.gov, plus criminal and license verification | Before first day |
| Current employees | LEIE batch comparison | Monthly |
| Contractors and vendors | LEIE and SAM.gov by entity name/EIN | At contracting, then monthly |
| Staffing placements | LEIE plus criminal screening | Before each assignment |
| Possible name match | SSN/EIN verification with OIG | Immediately |
Why the Exclusion Check Is Not Enough Alone
The LEIE shows only federal exclusions. It does not reveal recent arrests, pending charges, or falsified credentials. Pair it with criminal records searches, sex-offender registry checks, and employment and education verification. Reveal Background offers national criminal, county criminal, federal, sex-offender registry, MVR, employment and education verification, and SSN trace, all FCRA-compliant, with same-day results on most searches, no setup fee, and pay-per-report pricing. You can create an account to order these on each candidate. For pre-employment or post-incident drug testing, Reveal works with American Screening Corp.
Compliance Checklist
- Written policy requiring exclusion screening at hire and monthly
- Consent and disclosure forms when searches are part of a consumer report
- LEIE, state Medicaid, and SAM.gov all searched
- SSN/EIN verification for every potential match
- Dated screenshots or reports retained
- Adverse action process following FCRA if a decision relies on a report
- Contractors and vendors included
FAQ
What is an OIG exclusion check?
It is a search of the OIG’s LEIE to confirm a person or entity is not barred from federal health care programs.
How often should employers run an OIG exclusion list search?
Before hire or contracting and monthly afterward, since the LEIE is updated monthly.
Is the LEIE the only list to check?
No. Also check SAM.gov and each state’s Medicaid exclusion list where you operate.
What if an employee turns up on the list?
Verify with SSN, stop them from federally funded work right away, and consult legal counsel about repayment and disclosure.
Sources
- HHS OIG: Exclusions Program
- HHS OIG: LEIE Search
- FTC: Using Consumer Reports, What Employers Need to Know
This article is general information, not legal or medical advice.
