Monthly OIG exclusion screening
Check every employee and contractor against the OIG exclusion list and SAM.gov each month. We automate the download, matching, and record. A person verifies every possible match by SSN or EIN on OIG's site.
| Person or vendor | Result | Next |
|---|---|---|
| Sample, Robin RN | Clear | Stored 03/02 |
| Example Vendor LLC | Clear | Stored 03/02 |
| Test, Avery | Possible match | Verify SSN on OIG |
The LEIE download has no SSNs. A person verifies on OIG's site.
How it runs.
OIG updates monthly. Staff and vendors sit in HR and AP. An auditor will ask: can you show what you checked, and when?
Roster
Employees, contractors, vendors, former names from HR and AP.
Your dataMatch the lists
Full LEIE file and SAM exclusions, by name and DOB.
AutomatedA person verifies
SSN or EIN checked on OIG's search site.
A personDated record
Clear or possible match, with the outcome saved.
Automated
OIG LEIE download / SAM.gov Exclusions API / CSV / HRIS / Accounts payable
The rules and limits.
- Is it required
- OIG's 2013 bulletin says federal law does not require checking the LEIE, and that monthly screening best minimizes liability.
- The download
- A CSV of active exclusions. OIG recommends the full file over monthly supplements.
- Why a person
- The download has no SSNs or EINs. Verification happens on OIG's Online Searchable Database, up to five names at a time.
- SAM.gov
- Exclusions API needs a key, with daily request limits by account role. Its extract route returns up to 1,000,000 records as CSV or JSON.
- Penalty
- 42 USC 1320a-7a(a)(6) covers contracting with someone known or who should be known to be excluded.
What a person does.
- A person verifies every possible match by SSN or EIN on OIG's site.
- A person decides any employment, billing, or repayment step.
- Your compliance officer and counsel decide what your program requires, including state lists.
Where we stand: we have not shipped this for a healthcare organization. State Medicaid lists differ, so we add a state only after reading its file and terms.
Common questions.
Is a monthly check legally required?+
OIG says federal law does not require providers to check the LEIE. State programs and contracts can differ, so your counsel should confirm.
Why not send everyone's SSN through the OIG site automatically?+
We do not script OIG's search site. Monthly matching runs on the public download, and a person verifies the possible matches.
Does using you shift the liability?+
No. OIG says a provider that contracts out screening keeps the potential penalty liability.
Sources
- OIG: LEIE Database and Supplement Downloads
- OIG: Exclusions FAQ
- OIG: Special Advisory Bulletin, May 2013
- GSA: SAM.gov Exclusions API
- 42 USC 1320a-7a (Cornell LII)
General information, not legal, tax, or compliance advice. Rules change; confirm against the current source and your own advisers.
Bring us your version of this.
Intro calls are 30 minutes, free, and useful even if we never work together. We'll be honest about whether this is the right fit for your healthcare team.