Exclusion screening should be a repeatable compliance process, not a spreadsheet reviewed only when a payer asks for proof. The HHS Office of Inspector General maintains the List of Excluded Individuals/Entities (LEIE) to identify persons and organizations excluded from participation in federal health care programs. OIG’s published instructions recommend routine checks of new hires and current personnel, and explain how to use the downloadable database or monthly updates. Questions involving an actual exclusion notice may require Medicare enrollment, revocation, and OIG exclusion defense.
First, decide who belongs in the screening population
An employee list alone may miss contractors, temporary personnel, owners, practitioners, management personnel and organizations providing covered services. The correct universe depends on the healthcare entity, the relevant program and the roles performed. Build a roster containing legal name, previous names when relevant, organizational identifiers and active/inactive dates. Coordinate with human resources, credentialing, procurement and clinical leadership so one team does not assume another team has checked a person or entity.
Choose a reproducible search method
OIG offers an online search suitable for a small number of names and a downloadable full database for larger searches. For ongoing updates, OIG explains that users may refresh the full database or apply monthly supplement files. Its quick tips describe monthly database updates. Whatever method is chosen, keep a record of the source version, search method, roster screened, operator, date, matches requiring review and final resolution. An automated tool is only as reliable as its inputs and matching rules. Screening is also one recurring task to include in a documented Medicare compliance calendar.
Treat a possible match as a question to resolve
Common names and variations can create false positives. A screening process should define who performs secondary verification using OIG’s tools, who may access necessary identifying information, and who decides on an interim response. Do not label a person excluded merely because a similar name appears. At the same time, a credible match should not be ignored while normal billing continues without examination of applicable payment rules.
Understand the financial exposure
Exclusions can have serious consequences for claims involving services furnished, ordered or prescribed by excluded persons, depending on the facts and applicable program rules. OIG warns that organizations employing or contracting with excluded individuals and entities may face civil monetary penalties. A defensible compliance response may require stopping affected activity, preserving records, identifying implicated claims and consulting appropriate counsel. Do not equate every match with a final liability determination.
Build a monthly exception report
A useful management report records how many individuals and entities were screened, how many unresolved matches remained, whether new hires were checked before assignment, which departments failed to submit rosters and when exceptions were closed. Store the supporting export and verification record securely under an appropriate retention policy. Review whether staffing agencies, MSOs, labs, pharmacies and outsourced billing vendors have adequately allocated their own screening responsibilities.
What’s new in October 2026?
The key operational point is to use the OIG’s currently available LEIE data and not rely on a database downloaded months ago. OIG publishes update information and instructions on its official exclusions pages. The page’s update timestamp should be checked on the actual day of screening; a post’s publication date does not prove the source remains current.
BOLO Health Law advises healthcare businesses on regulatory exposure, audit responses, and outside legal and compliance counseling. Contact us if a possible exclusion affects your operations.
Primary references
OIG: LEIE Quick Tips and Instructions; OIG: LEIE Database and Supplement Downloads.
General legal information published October 16, 2026. Rules and contract language vary with the facts, payer and jurisdiction. Not legal advice; reading this article does not create an attorney-client relationship. BOLO Health Law is a New Jersey law firm and accepts matters subject to conflict, engagement and licensing requirements.