How to screen staff against the OIG exclusion list every month
If your practice bills Medicare or Medicaid, someone on your staff, a contractor or a vendor may be on a federal or state exclusion list without you knowing. This guide shows how to check them yourself, for free, every month, and how to keep a record that shows you did.
Why monthly
The HHS Office of Inspector General (OIG) says that "no Federal health care program payment may be made for any items or services furnished ... by an excluded person", and it can impose civil money penalties on a provider for each item or service an excluded employee or contractor furnished. Its guidance: "screening employees and contractors each month best minimizes potential overpayment and CMP liability." (Updated Special Advisory Bulletin on the Effect of Exclusion, May 8, 2013, linked from OIG's exclusions page.)
CMS told state Medicaid programs: "States should require providers to search the HHS-OIG website monthly" (State Medicaid Director Letter #09-001, January 16, 2009). OIG publishes its list updates monthly, so a monthly check catches each new update.
What to check
The OIG List of Excluded Individuals/Entities (LEIE). This is the main federal list for health care. Search it online from OIG's exclusions page, or download the whole database from oig.hhs.gov if you have a long roster.
SAM.gov exclusions. These are federal debarments and exclusions from every agency, not only health. Search them at sam.gov. You don't need an account to search.
Your state's Medicaid exclusion list. Many states keep their own list, and a person can be on a state list without being on the federal one. Search for your state Medicaid agency's "excluded providers" or "terminated providers" list.
The manual routine, step by step
Keep a roster. List everyone who works on anything billed to a federal program: employees, contractors, and the vendors you pay (billing companies, suppliers). Include each person's full legal name and any former or other last names. If you have their NPI or date of birth, add those too; they settle name matches.
Each month, search every name on every list. On the OIG search, try the last name alone as well as last plus first, because spelling and name order vary. Search businesses by their legal name and any "doing business as" name.
Treat a name match as a question, not an answer. Many people share a name. On the OIG search, a matching entry has a Verify step that compares the Social Security number (for people) or EIN (for businesses) you hold. On other lists, compare the NPI, date of birth, address or license number. SAM.gov entries rarely carry an NPI, so they usually need closer checking.
Keep a dated record. For each month, write down the date, which lists you searched, each list's update date, the names you checked, any close matches, and how you ruled each one in or out. Save the search result pages as PDFs. If you are ever audited, this record is how you show the checks happened.
If a match is confirmed, act at once. Stop the person's involvement in anything billed to a federal health program, and talk to your attorney or compliance adviser about what has already been billed. OIG's bulletin above explains the consequences, and OIG runs a Provider Self-Disclosure Protocol.
Limits to know
A search shows the list as of its last update. OIG adds exclusions monthly, and some take effect after they are listed.
No search proves someone is not excluded under another name. That is why other names, NPIs and dates of birth matter.
Exclusion lists are only one part of screening. License checks and your state's own rules may also apply.
This guide is general information, not legal or compliance advice. For your situation, ask your attorney or compliance adviser.
If you want it done for you: ClearRoster
ClearRoster runs the same monthly check on its own. You add your people and vendors once, and each month it checks them against the newest copy of each list it covers. It explains every close name and how to confirm or rule it out, remembers your decisions, and keeps a dated record of every check that you can download.
What it covers today: the OIG list and SAM.gov, plus 10 state Medicaid lists: Pennsylvania, New Jersey, California, Georgia, Indiana, North Dakota, Iowa, North Carolina, Maryland, Kentucky. Other states are not covered yet, and each record names every list it did not check. It never calls someone excluded on a name alone.
Price: a 14-day free trial with no card needed to start. After that it is $29 a month for up to 100 people and vendors, or $49 for up to 500. It is a record of a screening check, not legal or compliance advice.