Exclusion screening for ambulatory surgery centers

Start with the cap table, not the staff roster

ASC ownership is unusual in healthcare. The surgeons who operate are very often the investors who own the facility, so the same person can be a clinician, a referral source, and a partner on the LLC at once. That overlap is the first place an exclusion does real damage. Under 42 CFR 1001.1551, the OIG can exclude an entity when a person holding a direct or indirect ownership or control interest is excluded and knew, or should have known, of the conduct behind it. An excluded physician-investor or managing member is therefore not just a billing problem; the investment itself becomes a liability that can reach the whole center.

Yet most centers screen the people in scrubs and never run the same check on the LLC's members, the management company, or the governing board. When a center later self-discloses, that gap is usually the first thing examined. Put your owners and control persons on the screening list alongside everyone you employ.

Anesthesia, locums, and everyone you bill behind

A typical center's clinical labor is mostly not on its own payroll. Anesthesia is usually a contracted group billing under its own arrangement, surgeons hold privileges rather than W-2 status, CRNAs and first-assists rotate in by the case, and sterile processing or imaging may be vendor-supplied. Civil monetary penalty liability does not turn on employment classification. It attaches to any item or service furnished, ordered, or directed by an excluded person that lands on a federal claim, whether that person is an employee, a contractor, or a vendor's staff.

The contracted anesthesia group is the clearest case. It touches nearly every procedure, swaps its own clinicians in and out without necessarily telling the center, and rarely hands over its internal screening evidence. Those anesthesiologists and CRNAs belong on your roster, and so do locum surgeons, per-diem nurses, and any vendor whose people work inside a billed service.

Where exclusion screening meets Stark and anti-kickback

ASC ownership already lives under the anti-kickback statute. The ASC investment safe harbor at 42 CFR 1001.952(r) protects returns paid to physician-investors only when a set of conditions is met, and designated health services billed through the center can pull Stark into the analysis as well. So a compliant center already documents who its physician-owners are and vets those relationships against AKS and Stark.

Exclusion status is the natural next column in that same diligence file. An excluded physician cannot sit cleanly inside a safe-harbored investment, and an excluded referring physician compounds the exposure on both the kickback and the claims side. The strongest programs treat ownership exclusion screening as part of the AKS and Stark review they already run, rather than as a separate HR errand that happens once at onboarding.

What one excluded name actually costs an ASC

The enforcement record for surgery centers is small but expensive. Amarillo Endoscopy Center in Texas settled with OIG for $121,550 over a single excluded nursing assistant. The Center at Lowry, a Denver surgery center, agreed to pay $292,594 in December 2025 for employing one excluded registered nurse. Apex Dermatology and Skin Surgery Center settled for $125,070 after self-disclosing the same kind of violation.

The mechanics behind those figures are simple and unforgiving. Under 42 CFR 1003.210, OIG can assess up to $20,000 for each item or service an excluded person furnishes (before annual inflation adjustment), plus an assessment of up to three times the amount claimed, on top of repaying every dollar the program already paid. False Claims Act exposure can follow. Because one excluded clinician working a full surgical schedule generates hundreds of separately billable items, the per-item structure is what turns a payroll oversight into a six-figure settlement. State Medicaid lists matter for the same reason: a center that sees any Medicaid volume can be liable under a state sanction even after federal reinstatement, which is why all-state coverage ships on every Provider Signals plan rather than as an upsell.

Screening that keeps pace with a roster in motion

The LEIE is refreshed monthly, and OIG's stated expectation is to screen on hire and monthly afterward. A check run once at credentialing tells you nothing about the surgeon added next quarter or the anesthesiologist the contract group rotated in last week. Provider Signals is built for that churn:

• Owners and control persons sit on the roster next to staff, so an excluded investor or managing member never escapes the screen.
• Contracted clinicians and vendors (anesthesia groups, locum surgeons, per-diem nurses, sterile-processing partners) go on the list like anyone whose work you bill behind.
• Continuous re-screening checks new additions on day one and re-runs the whole roster on every refresh, so a clean file in January does not become a liability in June.
• Audit-ready output gives you a dated, exportable record of every screen for your accreditor, Medicare survey, payers, and compliance binder.

What it costs, and how we compare

The established screening vendors are enterprise-priced, commonly $15,000 to $200,000 a year, and many still bill state Medicaid coverage as an upgrade. That rarely fits a single-site ASC or a lean management group. Provider Signals delivers the same continuous, all-source monitoring on a self-serve basis, sized to the number of providers you actually track.

OIG expects screening on hire and again every month. Provider Signals runs it continuously, so the check is never out of date. See how the workflow runs on the exclusion screening overview, compare other segments on the industry hub, or size your roster on the pricing page.

How we match your roster

Exclusion screening is only as good as its matching. We match each person or entity against every source using the full identifier set together — NPI, first name, last or organization name, city, state, and ZIP — never one field alone. NPI alone misses records (the OIG LEIE and many lists don’t carry an NPI for every entry); a name or a location alone produces false matches on common names. When a source record has no NPI, we fall back to name plus location.

Because accuracy depends on your input, provide complete, correct details for every roster entry. When more than one possible match is found, we show you all candidates with their source records so you can confirm, select, or merge — we never auto-flag anyone as excluded. Always verify a match against the primary source before taking any action.

Frequently asked questions