An exclusion screening program is the written policy and routine an organization uses to check its workforce, contractors and vendors against the federal exclusion lists, chiefly the HHS Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE) and SAM.gov, so it does not pay for or bill items and services tied to an excluded person. It is for providers, plans, pharmacies and vendors that bill or contract with federal health care programs. Integral Healthcare Solutions (IHS) drafts the program: a gap assessment, a scope map of who is screened against which list, the written policy and monthly procedure, and match-resolution and documentation templates.
Last reviewed: October 2026.
What is exclusion screening?
The core OIG guidance is OIG's "Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs," issued May 8, 2013, which "replaces and supersedes the 1999 Bulletin" (OIG bulletin; listed on the OIG compliance alerts index). It explains the payment consequence: "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 bulletin). The prohibition "applies to all methods of Federal health care program payment," including capitated payments and bundled payment systems.
The regulation on the scope and effect of exclusion, 42 CFR 1001.1901 (eCFR current as of September 30, 2026), states that "no payment will be made by Medicare, including Medicare Advantage and Prescription Drug Plans, Medicaid, or any other Federal health care program for any item or service furnished, on or after the effective date specified in the notice" by an excluded individual or entity.
The lists:
- OIG LEIE. A searchable database with downloadable monthly supplements; the OIG page showed a last update of September 10, 2026 when reviewed (OIG LEIE).
- SAM.gov exclusions. GSA's System for Award Management, with exclusion types described on SAM.gov and a public API (GSA Exclusions API). Older rules and guidance still name EPLS; the OIG bulletin explains, "In July 2012, GSA migrated its Excluded Parties List System (EPLS) and other systems to the new SAM."
- State Medicaid exclusion lists. The sources reviewed for this page do not include any state list, so this page does not describe them. The scope map records the state lists your contracts or state programs require, taken from each state's own source.
Who needs it and what triggers it
For most providers, screening is OIG's recommended practice rather than a stated rule. In 2013 OIG wrote: "Providers are not required by statute or regulation to check the LEIE," but "OIG updates the LEIE monthly, so screening employees and contractors each month best minimizes potential overpayment and CMP liability" (OIG bulletin, Frequency of Screening). The duty is firmer for others:
- State Medicaid agencies must "Check the LEIE and EPLS no less frequently than monthly" (42 CFR 455.436(c)(2)), and OIG says they "should be checking the OIG's List of Excluded Individuals/Entities (LEIE) on a monthly basis, and in connection with any new enrollments" (OIG Guidance for State Medicaid Agencies).
- Medicare Advantage and Part D sponsors are told by CMS guidelines to review the LEIE and the GSA list "prior to the hiring or contracting of any new employee, temporary employee, volunteer, consultant, governing body member, or FDR, and monthly thereafter" (Chapter 21 / Chapter 9, section 50.6.8). See Medicare Advantage and Part D compliance program.
- Vendors and contractors whose customer contracts include screening terms take on the duties those contracts state.
How IHS helps
- Gap assessment. IHS compares your current screening with OIG's bulletin, 42 CFR 1001.1901, 42 CFR 455.436 where it applies to your organization type, and the screening duties in your contracts.
- Scope map. IHS lists each workforce and contractor category and each list it is checked against, and how often.
- Drafting. IHS drafts the written policy, the monthly procedure, and templates for resolving possible matches and documenting each search, for your compliance officer and counsel to approve. For Medicare Advantage and Part D clients, IHS maps the program to Chapter 21 / Chapter 9.
- Mock audit. IHS samples screening records and checks them against the procedure.
What your organization supplies: workforce and contractor rosters by category, current screening records, vendor screening reports if a vendor runs the checks, and the contracts that impose screening duties.
The limit: your staff or your chosen vendor performs the checks. Your compliance officer and counsel decide how to handle any match and own any disclosure; your organization submits anything that goes to a regulator. IHS gives no legal advice.
Related IHS pages: Compliance Services, Compliance Program Development and CMS program audit readiness.
What to have ready
Each item ties to the OIG bulletin (May 8, 2013), the eCFR (current as of September 30, 2026) or CMS guidelines.
- A roster of employees and contractors by category. OIG says providers "should determine whether or not to screen contractors, subcontractors, and the employees of contractors using the same analysis that they would for their own employees" (OIG bulletin).
- Your current screening schedule, to compare with OIG's monthly recommendation (OIG bulletin).
- Saved search results. OIG says providers "should maintain documentation of the initial name search performed (such as a printed screen-shot showing the results of the name search) and any additional searches conducted" (OIG bulletin).
- Records of how past possible matches were resolved. The LEIE download files omit SSNs, so "you'll need to use the Online Search to verify specific individuals and entities" (OIG LEIE).
- Your screening vendor's contract and reports, if you use one (OIG bulletin).
- Contracts with payers or plans that impose screening duties, including Medicare Advantage or Part D FDR terms (section 50.6.8).
- The list of state Medicaid programs you bill or contract with.
- Your current written screening policy, if any, and who owns it.
To go through the list with IHS, book the introductory call below.
How it compares
| Choice | What the sources say |
|---|---|
| LEIE only, or LEIE plus SAM.gov | The OIG bulletin discusses "the distinction between the information that appears on the LEIE and the information that appears on the General Services Administration's (GSA) System for Award Management (SAM)" (OIG bulletin). IHS reads that section with your counsel when setting scope. |
| A commercial screening vendor | Liability stays with you: "the providers will retain the potential CMP liability if they employ or contract with an excluded person" (OIG bulletin). |
| In-house screening by staff | Same liability, with the work and documentation done by your staff under your procedure. |
| Adding other databases | The bulletin names the National Practitioner Data Bank as another system that reports adverse actions. Whether to add it is a scope decision for your organization. |
What it costs
The OIG LEIE search and download pages we reviewed show no charge, and the GSA API page describes registered users requesting a public API key with no fee stated. No agency publishes a fee schedule for building a screening program on the pages we reviewed; costs depend on scope, such as workforce size and the number of contractor categories. IHS scopes each engagement after a free introductory call.
What this is not
- This page is not legal advice. IHS is a consulting firm, not a law firm.
- IHS does not run your monthly checks or decide whether a match is a true match.
- IHS does not contact, report to or submit anything to OIG, CMS or any state agency. IHS drafts; your organization submits.
Frequently asked questions
What does an OIG exclusion mean for the items and services we bill or pay for?
OIG's 2013 bulletin states that no federal health care program payment may be made for items or services furnished by an excluded person, or at the medical direction or on the prescription of an excluded person. The prohibition applies to all payment methods, including capitated and bundled payments. 42 CFR 1001.1901 states the same rule for Medicare, including Medicare Advantage and Part D plans, Medicaid and other federal programs.
Are providers required to check the LEIE?
In its 2013 bulletin OIG said providers are not required by statute or regulation to check the LEIE. The OIG alerts index we reviewed lists no later bulletin on the point, and your contracts, payer terms and state program rules may still require screening. It also says that, because it updates the LEIE monthly, screening employees and contractors each month best minimizes potential overpayment and civil monetary penalty liability. State Medicaid agencies and Medicare Advantage and Part D sponsors have their own stated duties.
Which lists do we check?
The OIG LEIE and SAM.gov are the federal lists. OIG's bulletin discusses how the information on the two differs, and IHS reads that section with your counsel when setting scope. State Medicaid exclusion lists depend on the states you work in; IHS records them from each state's own source.
How often should we screen?
OIG updates the LEIE monthly and says monthly screening best minimizes potential overpayment and penalty liability. State Medicaid agencies must check no less than monthly under 42 CFR 455.436(c)(2). CMS guidelines tell Medicare Advantage and Part D sponsors to screen before hiring or contracting and monthly after that.
Do we have to screen our contractors' employees?
OIG says providers should decide whether to screen contractors, subcontractors and the employees of contractors using the same analysis they would use for their own employees. IHS writes that analysis into the scope map so the decision for each category is recorded.
What do we do with a possible match?
The LEIE download files do not include SSNs, because the Privacy Act prohibits distributing them. OIG's download page says you need to use the Online Search to verify specific individuals and entities. IHS drafts the match-resolution template; your compliance officer and counsel decide what follows a confirmed match.
What documentation proves we screened?
OIG says providers should keep documentation of the initial name search, such as a printed screen shot of the results, and of any additional searches used to check possible matches. IHS builds the documentation template into the monthly procedure.
If a vendor does our screening, does the liability move to the vendor?
No. OIG states that because it is the provider's responsibility to determine whether employees are excluded, providers retain the potential civil monetary penalty liability if they employ or contract with an excluded person. The vendor contract and the vendor's reports become part of your evidence.
How do duties differ for a State Medicaid agency, a Medicare Advantage or Part D sponsor and a provider?
A State Medicaid agency must check the LEIE and the federal list no less than monthly under 42 CFR 455.436. Medicare Advantage and Part D sponsors follow CMS guidelines calling for screening before hiring or contracting and monthly after. For other providers, OIG recommends monthly screening but stated in 2013 that there is no statutory or regulatory requirement to check the LEIE.