Exclusion Screening Process: Step-by-Step Guide for OIG, SAM.gov & State Lists

Exclusion Screening Purpose

Exclusion screening protects your organization from hiring or contracting with individuals or entities barred from federal benefits or contracting. You screen names against the OIG List of Excluded Individuals/Entities, the SAM.gov Excluded Parties List, and applicable State Exclusion Lists.

The goals are clear: prevent Federal Program Exclusions from impacting your claims, block ineligible vendors from federal awards, and strengthen Healthcare Program Fraud Prevention. Robust Exclusion Verification Procedures also demonstrate Federal Contract Compliance and reduce overpayment, penalty, and reputational risk.

You should screen pre-hire, pre-credentialing, pre-contract, and on a defined cadence (commonly monthly). Document every step to produce a defensible audit trail and to drive timely remediation if matches appear.

Gather Screening Information

Define your screening population and cadence

Include employees, licensed practitioners, medical staff, contractors, temps, volunteers, owners, board members, referral sources, and vendors with access to federally reimbursed work or federal funds. Apply screening at onboarding and continue at least monthly, with ad hoc checks upon role changes or new locations.

Standardize identity and match fields

Collect full legal name, aliases/maiden names, date of birth, last four of SSN (where lawful), NPI, professional license numbers, and addresses. For entities, gather legal name, DBA/trade names, UEI, EIN, and prior names. Quality data reduces false positives and speeds determinations.

Prepare documentation and audit trail

Maintain a written policy describing scope, sources, frequency, and responsibilities. Use a central log to record who screened, when, what lists were queried, parameters used, and outcomes. Retain evidence files (search results, exports, or screenshots) per your retention schedule.

Screen Against OIG LEIE

Run the search and capture evidence

Search the OIG List of Excluded Individuals/Entities by exact name and known identifiers (for example, NPI or license). Record the date, search terms, and results. If there is no result, note “no record found” and save proof of the query.

Resolve potential matches

When a name match appears, compare secondary identifiers such as date of birth, NPI, license number, and address history. If uncertainty remains, treat it as a potential match and pause onboarding or work assignment until you complete Exclusion Verification Procedures and make a written determination.

Embed frequency and oversight

Repeat LEIE checks at least monthly for the in-scope population. Periodically sample determinations for quality, verify that aliases are checked, and reconcile staff rosters against screening logs to confirm complete coverage.

Screen Against SAM.gov Excluded Parties List

Search by UEI or legal name

Query the SAM.gov Excluded Parties List using the entity’s UEI or the individual’s or entity’s legal name and prior names. Capture the record details, including status (active or inactive), excluding agency, cause, scope (procurement/nonprocurement), and any termination or review dates.

Interpret scope for contracting decisions

Active exclusions generally bar receipt of federal awards and subawards, and can restrict roles on federally funded projects. Map findings to your procurement and subcontractor approval steps to ensure Federal Contract Compliance before obligating funds or executing agreements.

Document outcomes and controls

Note any restrictions or special conditions, and update vendor master files to block contracting with excluded parties. Re-screen key vendors monthly and before each new award, option year, or task order.

Screen State Exclusion Lists

Identify all relevant jurisdictions

Check State Exclusion Lists for every state where you operate, bill, provide services, or where the individual has lived or worked. Many states maintain Medicaid or program-specific exclusion rosters that must be reviewed alongside federal sources.

Search consistently and record proof

Use standardized name formats and available identifiers (license numbers or NPIs) for each state site. Record the search date, criteria, and results for every jurisdiction queried, and retain artifacts to support audits and payer enrollment requirements.

Account for differences across states

Update schedules to reflect each state’s refresh cadence and data format. Where a state shows a potential match but limited identifiers, escalate for manual verification before making a final decision.

Analyze Screening Results

Classify outcomes

Sort results into three groups: no record found, potential match, and confirmed exclusion. For potential matches, require secondary identifiers and documented review. For confirmed exclusions, determine whether the scope affects federal healthcare benefits, federal contracting, or both.

Apply a decision framework

• No record found: proceed, retain evidence, and include in monthly monitoring.
• Potential match: pause onboarding/work, collect additional identifiers, and document the final disposition.
• Confirmed exclusion: remove from affected duties, assess impact on claims or contracts, and initiate remediation steps.

Strengthen program integrity

Trend findings to spot control gaps, such as missed aliases or delayed rosters. Use metrics—screening timeliness, match resolution time, and false-positive rates—to refine processes and support Healthcare Program Fraud Prevention.

Implement Actions for Excluded Individuals

Immediate containment

For vendors, suspend purchasing and performance under federal awards. Notify internal stakeholders, secure records, and prevent further exposure.

Financial and contractual remediation

Identify the service dates affected by the exclusion, hold or retract related claims or invoices, and evaluate repayment or contract remedies as required. Update credentialing files and vendor records to reflect ineligibility and block re-engagement.

Documentation, training, and monitoring

Issue a written determination, including the evidence used and the effective date of action. Retrain managers on Exclusion Verification Procedures, expand alias capture, and automate monthly monitoring with alerts and exception workflows.

Reinstatement considerations

An individual or entity remains ineligible until formally reinstated by the listing authority. Require written proof of reinstatement and complete full screening before any return to federally reimbursed roles or federal contracting.

Conclusion

A reliable exclusion screening process checks OIG LEIE, SAM.gov, and State Exclusion Lists with standardized data, monthly monitoring, and documented decisions. These practices reduce Federal Program Exclusions risk, strengthen Healthcare Program Fraud Prevention, and demonstrate ongoing Federal Contract Compliance.

FAQs

What is the purpose of exclusion screening?

The purpose is to ensure you do not employ, credential, or contract with parties barred from federal healthcare benefits or federal contracting. Effective screening protects claims and awards, prevents penalties, and supports a culture of compliance.

How do I screen candidates against OIG LEIE?

Collect full identifiers, search the LEIE by name and NPI, compare secondary details to resolve matches, and document the outcome. If a potential match remains, pause onboarding and complete formal verification before making a final decision.

When should state exclusion lists be checked?

Check at onboarding or pre-contract, then at least monthly. Screen all states where you operate, bill, provide services, or where the individual has lived or worked, and retain evidence for each jurisdiction.

What actions are required if an excluded individual is found?

Immediately remove the person from federally reimbursed or federally funded work, block related claims or invoices, assess and remediate financial exposure, document the determination, and strengthen controls to prevent recurrence.