OIG Exclusion List & SAM.gov Checks: A Healthcare Compliance Guide

An OIG exclusion list check helps healthcare employers identify individuals and entities excluded from federal healthcare programs. Along with SAM.gov checks, it helps hospitals, clinics, and staffing agencies identify potential compliance risks before hiring employees or working with contractors. However, searching the wrong database or failing to verify a possible match can leave gaps in your screening process.

For healthcare employers across the United States, understanding these checks is essential to managing hiring risks and protecting federal program payments. Sapphire Check offers healthcare background checks to help organizations screen candidates and make informed hiring decisions.

What Is an OIG Exclusion List Check?

An OIG exclusion list check searches the List of Excluded Individuals/Entities (LEIE), which the U.S. Department of Health and Human Services Office of Inspector General maintains. It helps healthcare organizations determine whether an individual or entity is excluded from Medicare, Medicaid, and other federal healthcare programs.

What is the OIG exclusion list?

The LEIE is the official database of individuals and entities excluded by HHS OIG.

Federal healthcare programs generally cannot pay for items or services furnished, ordered, or prescribed by excluded individuals. This restriction can also affect administrative and support services connected to federally reimbursed care.

Why are individuals and entities excluded?

Federal law establishes two main exclusion categories:

• Mandatory exclusions: Apply to specified offenses, including certain healthcare fraud convictions and convictions involving patient abuse or neglect.
• Permissive exclusions: Allow OIG to exclude individuals or entities for other specified conduct, including certain licensing actions and misdemeanor offenses.

The grounds and exclusion periods vary. The OIG Exclusions Program provides information about exclusion authorities and their effects.

How Do You Perform an OIG Exclusion List Check?

Employers can perform an OIG exclusion list check through the official LEIE online database. The process involves searching an individual’s legal name or an entity’s name, reviewing potential matches, verifying identity when necessary, and documenting the results. OIG also provides a downloadable database for organizations screening larger groups.

Step 1: Open the official LEIE database

Visit the official OIG exclusion search and select the appropriate search option.

The online database supports searches for up to five individuals or entities at once. Employers with larger screening rosters can use the downloadable LEIE database.

Step 2: Enter the correct name

Enter the individual’s legal name or the entity’s name. Check known former names, relevant spelling variations, and hyphenated names.

OIG recommends checking name variations because the LEIE may contain the name known to OIG when the exclusion occurred.

Step 3: Review the search results

Compare potential matches with the candidate’s available identifying information.

A matching name alone does not confirm an exclusion. Common names and similar identifying details can produce results that require additional verification.

Step 4: Verify a potential match

When a potential match appears, employers should use OIG’s official online verification function to confirm the individual’s identity using an SSN or the entity’s identity using an EIN. A matching name alone is insufficient to confirm an exclusion.

OIG provides this verification function through its online searchable database. Employers using downloaded LEIE records must also use the online tool to complete SSN or EIN verification.

Step 5: Document the results

Record the name searched, search date, database, results, and any additional verification steps.

OIG advises organizations to maintain documentation of initial searches and efforts to verify potential matches. Employers should also retain the final determination for their screening records.

For further guidance, follow the official LEIE search instructions.

Who Needs an OIG Exclusion List Check?

Healthcare organizations should assess exclusion risks for employees, contractors, and entities whose work contributes to federally reimbursed services. Screening may extend beyond direct patient care to administrative, management, and support activities. The appropriate screening scope depends on the organization’s operations and applicable federal, state, and contractual requirements.

Healthcare employers should consider screening relevant personnel and entities, including:

• Physicians, nurses, therapists, and other clinical professionals.
• Temporary, per-diem, and agency healthcare workers.
• Billing, coding, and administrative personnel.
• Contractors and vendors supporting federally reimbursed services.
• Relevant managing employees, owners, and board members.

For example, a hospital may need to assess exclusion risks involving a billing contractor even if that contractor never treats patients.

Employers should maintain an accurate screening roster and evaluate the responsibilities of everyone involved in federally funded services.

How Often Should Employers Check the OIG Exclusion List?

OIG recommends checking the LEIE before hiring or contracting with individuals and periodically afterward. Because OIG updates the database monthly, monthly screening helps reduce potential overpayment and civil monetary penalty risks. Employers must also review applicable state Medicaid requirements, enrollment conditions, and payer contracts to determine their specific obligations.

Pre-employment and ongoing screening

Healthcare employers should establish a written screening schedule that covers new hires and existing personnel.

The following framework can help organizations plan their screening activities.

Screening stage	Purpose
Pre-employment	Identify exclusions before hiring
Pre-contract	Check relevant contractors and entities
Monthly	Identify newly reported exclusions
Event-driven	Investigate changes or potential compliance concerns

Is monthly screening mandatory?

OIG’s general guidance recommends monthly LEIE screening but does not establish a universal federal mandate requiring every healthcare provider to conduct monthly searches.

Separate state Medicaid rules, contracts, and other requirements may impose specific obligations.

The OIG Special Advisory Bulletin on the Effect of Exclusion explains the screening recommendations and potential consequences of employing excluded individuals.

What Should Employers Do if an OIG Exclusion Check Finds a Match?

A possible LEIE match requires further investigation before an employer concludes that someone is excluded. Employers should compare available identifying information, complete the official verification process, and document their findings. If the exclusion is confirmed, the organization should involve its compliance team and assess any affected services or claims.

How to verify a possible match

Consider a hospital screening a nurse who shares the same name as someone listed in the LEIE. The hospital should compare the available identifying details and use OIG’s official SSN verification function to confirm the potential match. It should not treat the matching name alone as proof of exclusion.

If the hospital confirms the exclusion, its compliance team should assess the nurse’s duties and any federal healthcare program implications.

What happens after a confirmed exclusion?

An employer should promptly assess the individual’s involvement in federally reimbursed services and determine appropriate restrictions.

If the person has already performed relevant work, the organization may need to review affected claims, repayment obligations, and potential disclosure requirements. Qualified legal counsel can help determine the appropriate response.

What Are the Penalties for Employing Excluded Individuals?

Employing or contracting with an excluded person can create significant financial risks when their work involves federally payable items or services. Depending on the circumstances, an organization may face repayment obligations, civil monetary penalties, and other enforcement consequences. These risks can extend beyond direct clinical care to administrative and support activities.

Financial and compliance consequences

For example, a healthcare organization that bills Medicare for services involving an excluded employee may need to review the affected claims and determine whether repayment is necessary.

Penalties depend on the applicable law and circumstances. Employers should not rely on outdated penalty figures because federal civil monetary penalty amounts can change.

What Is the Difference Between LEIE, SAM.gov, and State Exclusion Lists?

LEIE, SAM.gov, and state exclusion lists identify different restrictions. LEIE contains exclusions imposed by HHS OIG, while the System for Award Management (SAM) provides broader federal exclusion information. State databases may contain Medicaid exclusions and other state-specific restrictions. Healthcare employers should determine which sources their screening obligations require.

LEIE vs. SAM.gov

These databases serve different purposes, so employers should not treat them as interchangeable.

Database	Primary purpose
LEIE	Identifies exclusions imposed by HHS OIG
SAM.gov	Provides government-wide exclusion information
State exclusion lists	Identify exclusions and restrictions under applicable state programs

Employers can search the SAM.gov exclusions database to review government-wide exclusion information.

When should employers check state exclusion lists?

State Medicaid requirements and payer agreements may require additional searches.

For example, a healthcare staffing agency placing nurses in several states should evaluate the applicable state exclusion databases for each placement.

Is an OIG Exclusion Check the Same as a Criminal Background Check?

An OIG exclusion check is not the same as a criminal background check. OIG screening identifies exclusions from federal healthcare programs, while criminal background checks search criminal record sources. Healthcare employers may need both because a clear criminal history search does not establish that a candidate is absent from the LEIE.

Why healthcare employers may need both

Different screening methods help employers identify different risks.

An OIG search focuses on federal healthcare exclusions. Criminal searches review relevant criminal records, while professional license verification helps confirm a candidate’s credentials.

Sapphire Check’s healthcare background checks help employers combine relevant searches based on their hiring needs.

How Do FACIS and Healthcare Sanctions Background Checks Support OIG Screening?

FACIS and healthcare sanctions background checks help employers review exclusion and disciplinary information across multiple sources. They complement a direct LEIE search by providing broader federal and state screening coverage. The available sources depend on the screening product, so employers should confirm which databases and screening levels their selected service includes.

FACIS screening and healthcare sanctions

FACIS stands for Fraud and Abuse Control Information System. It brings together healthcare-related exclusions, sanctions, and disciplinary information. A FACIS background check helps healthcare employers review regulatory information beyond a standalone LEIE search.

Sapphire Check’s FACIS and Healthcare Sanctions Screening searches OIG, GSA/SAM, and other federal agency data. Its Healthcare Sanction Report also includes disciplinary information reported by all 50 states.

Employers can explore Sapphire Check’s guides to FACIS Level 3 searches and healthcare sanctions background checks to understand broader screening coverage.

Sapphire Check offers healthcare sanctions screening as a standalone service or as part of a customized healthcare screening package. Employers should confirm how the selected report maps to any FACIS level their organization requires.

How Can Employers Manage Ongoing Exclusion Screening?

An effective exclusion screening program needs an accurate roster, a consistent search schedule, and clear documentation. Employers should assign responsibility for screening, investigate unresolved matches, and review their records regularly. A structured process helps HR and compliance teams identify potential exclusions and respond before they create further risks.

Maintain accurate screening records

Each screening record should identify the individual or entity, database searched, date, search results, and reviewer.

Employers should also document additional identity verification and the final determination. Store records securely and follow applicable retention requirements.

Manual vs. outsourced screening

Manual LEIE searches can work for organizations with smaller screening rosters. Larger healthcare companies may need additional support managing multiple databases and recurring checks.

Consideration	Manual screening	Outsourced screening
Workload	Managed internally	Provider conducts agreed searches
Database coverage	Depends on internal process	Depends on purchased services
Documentation	Employer maintains records	Provider supplies available reports
Match resolution	Employer investigates	Depends on provider’s services

Sapphire Check’s healthcare sanctions screening service helps employers bring federal and state sanctions information into one report. Employers should confirm the service’s monitoring options and verification procedures against their specific requirements.

Conclusion

Accurate OIG exclusion list and SAM.gov checks help healthcare employers identify excluded individuals, manage hiring risks, and protect federal healthcare program payments.

Sapphire Check offers customizable background screening packages, including healthcare sanctions screening, to support organizations across the United States. Contact us to discuss your healthcare screening requirements and find a package that fits your organization.

FAQs

Is an OIG exclusion list check free?

Yes. HHS OIG provides free access to its online LEIE search and downloadable database. Employers can use these resources to screen individuals and entities. Third-party screening providers may charge for additional services.

How long does an OIG exclusion list check take?

The time depends on the number of names searched and whether potential matches require verification. The official online database supports searches for up to five individuals or entities at once. Larger screening volumes and unresolved matches may require additional time.

Can employers search the OIG exclusion list using an SSN?

Employers can use an SSN to verify a potential individual match through the official online database. They must first conduct a name search and identify the possible match. OIG does not include SSNs in its downloadable LEIE database.

Does an OIG exclusion check include SAM.gov?

No. LEIE and SAM.gov are separate databases. An OIG check does not automatically establish whether someone appears in SAM.gov. Employers should search the applicable sources based on their compliance requirements.

Can someone be removed from the OIG exclusion list?

Yes. Eligible excluded individuals and entities may apply for reinstatement. Reinstatement is not automatic when an exclusion period ends. Employers should verify official reinstatement status before treating an exclusion as resolved.

Can a background check company perform OIG exclusion screening?

Yes. Employers can use a background screening provider to conduct exclusion searches. They should verify the provider’s database coverage and reporting procedures before choosing a service. Outsourcing does not eliminate the employer’s responsibility for addressing exclusion-related compliance risks.