Provider Signals™OIG exclusion screening best practices
A defensible exclusion-screening program comes down to five things: screen the right people, against the right lists, at the right frequency, with documentation, and without manual gaps. Here's the checklist.
1. Screen everyone — not just billing providers
Include employees, contractors, vendors, locum/temp staff, and governing-body members. Federal programs won't pay for anything an excluded party furnishes, orders, or prescribes, so the screening population is broader than your claims roster.
2. Screen the right lists
- OIG LEIE — the federal system of record (required).
- SAM.gov — government-wide debarments (why both).
- State Medicaid lists — for every state you operate in (the patchwork).
3. Screen at the right frequency — monthly
Screen before hire or contracting, then re-screen monthly to match the LEIE's monthly updates. See monthly exclusion screening for why the cadence matters.
4. Document every run
Keep dated, exportable records of who was screened, against which lists, on what date, and the result. In an audit, the documentation is the program — undocumented checks don't help you.
5. Eliminate manual gaps with monitoring
Spreadsheets and one-by-one lookups break down past a few dozen names and create blind spots between checks. Continuous monitoring re-screens your full roster automatically and alerts you on new matches.
The program at a glance
Pre-hire screening
Screen every individual and entity before they start or sign — across the LEIE, SAM.gov, and state lists.
Re-screen the roster
Re-check everyone each month against the latest LEIE update; investigate and resolve potential matches.
Document & act
Keep an exportable audit trail and act immediately on a confirmed exclusion — before the next claim.
Frequently asked questions
How often should you run OIG exclusion screening?
Screen before hire or contracting, then re-screen monthly — the OIG updates the LEIE monthly and recommends monthly screening of employees, contractors, and vendors.
Who needs to be screened?
Employees, contractors, vendors, temporary/locum staff, and governing-body members — not just the providers on your claims.
What records should we keep?
Dated, exportable evidence of who was screened, against which lists, when, and the outcome. In an audit, the documentation demonstrates the program.
Can exclusion screening be automated?
Yes. Continuous monitoring uploads your roster once and re-checks it against each federal refresh, alerting you to new matches and maintaining the audit trail automatically.
Data & methodology
Sources: OIG LEIE, CMS NPPES. This page is informational and does not constitute legal or compliance advice.
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