How to Do OIG Exclusion Screening for Your Telehealth Company

OIG Exclusion Screening Requirements

OIG exclusion screening ensures you do not employ or contract with individuals or entities that are excluded from federal health care programs. If an excluded person contributes—directly or indirectly—to an item or service billed to Medicare, Medicaid, or other federal programs, payment is prohibited and you may owe an overpayment. For telehealth companies, this touches both clinical and nonclinical roles that drive billable services.

Who you must screen

• Licensed clinicians (physicians, NPs, PAs, therapists), supervisors, and medical directors.
• Revenue cycle personnel (coders, billers, utilization review), schedulers, clinical support (scribes, care coordinators) whose work supports claims.
• Telepresenters, call-center staff, remote contractors and per-diem providers working across states.
• Owners, officers, and key management; high-risk vendors (e.g., staffing agencies, BPOs, interpreter services).

An “exclusion” is a federal program exclusion imposed by HHS OIG. Your obligation is to prevent excluded individuals and entities from furnishing or contributing to federally reimbursed items or services and to maintain exclusion screening compliance under applicable federal healthcare regulations.

Core databases you must know

• List of Excluded Individuals and Entities (LEIE) maintained by HHS OIG.
• General Services Administration System for Award Management (SAM), which lists government-wide debarments and suspensions relevant to contracting and vendor risk.

Screening the LEIE is essential. Screening SAM strengthens your vendor and contracting controls, especially if you rely on outsourced or marketplace providers.

Screening Frequency and Updates

Screen before onboarding and then screen on a recurring cadence. The widely adopted standard is monthly LEIE screening to promptly catch new exclusions and mitigate overpayment exposure. Apply the same cadence to high-risk vendors and contractors.

Event-driven rechecks

• Name changes, new or updated licenses, or NPI changes.
• Role transitions into billable or supervisory functions.
• Breaks in service or reactivation of contracts.
• Adverse actions or board-of-medicine updates surfaced by credentialing.

For multi-state telehealth operations, add monthly checks of state Medicaid exclusion lists in the states where you bill or have a physical nexus, because state requirements can be stricter than federal baselines.

Operationalizing the cadence

• Automate monthly queries and exception reporting for your active workforce and vendor roster.
• Align rechecks with payroll and credentialing cycles to avoid gaps when people change roles or locations.
• Document all “no hit” results the same way you document matches, so you can prove continuous monitoring.

Consequences of Non-Compliance

Hiring or retaining excluded individuals who contribute to federally reimbursed services can trigger civil monetary penalties, mandatory repayments of tainted claims (overpayments), and potential False Claims Act exposure. Contracts with payers may be terminated, and your organization can face program exclusion risks of its own.

Financial consequences are often paired with operational disruption: claim denials, recoupments, corrective action plans, and possible corporate integrity agreements. Reputational harm and operational downtime frequently exceed the direct penalties.

If you identify a past involvement by an excluded person, stop participation immediately, assess the date range and claims affected, calculate the overpayment, and follow your disclosure and repayment obligations (including the 60‑day overpayment rule). Document each step and consult counsel as needed.

Screening Process and Databases

Step 1 — Define scope and policy

• Write an enterprise policy that applies to employees, contractors, volunteers, students, owners, and material vendors.
• Map which roles influence billable telehealth services, including coding, documentation, and supervision.

Step 2 — Collect identifiers

• Gather legal name, known aliases, date of birth, professional license numbers, and NPI (if applicable).
• Use the last four digits of SSN for verification when permitted and necessary; avoid collecting full SSNs unless essential.

Step 3 — Search the LEIE

• Run monthly searches of the List of Excluded Individuals and Entities (LEIE) using names and NPIs.
• For potential matches, verify with second identifiers (DOB, last 4 SSN, license number) before concluding a “hit.”
• If a match is confirmed, immediately remove the individual from any federally reimbursed work and begin remediation.

Step 4 — Search SAM

• Check the General Services Administration System for Award Management (SAM) for debarments and suspensions.
• Apply SAM screening to vendors, staffing partners, telehealth marketplaces, and high-risk contractors.

Step 5 — Check state exclusion lists when applicable

• Monitor state Medicaid exclusion lists in each state where you deliver or bill telehealth services.
• Document state-specific results alongside federal findings to satisfy payor and auditor expectations.

Step 6 — Resolve matches

• Maintain a verification workflow that requires two identifiers before confirming any exclusion.
• On confirmation, segment affected claims, quarantine scheduling and billing for the lookback period, and initiate overpayment and disclosure processes.

Step 7 — Integrate into daily operations

• Embed screening into onboarding, credentialing, reappointment, and vendor onboarding/renewal.
• Set calendar-based and event-driven triggers so changes (e.g., new licensure state) generate immediate rechecks.

Documentation and Recordkeeping

Good records make or break audits. Keep artifacts that show you screened the right people at the right times and took prompt action on any issues.

What to retain

• Policy and procedures governing exclusion screening, including scope and cadence.
• Active rosters for workforce and vendors, with unique identifiers used for screening.
• Monthly LEIE and SAM results (including “no hit” logs), date/time stamps, and the user or system that performed the check.
• Match verification notes, supporting identifiers used, and final determinations.
• Corrective actions: removal from duties, claim impact analyses, disclosures, and repayments.
• Signed workforce and vendor attestations about exclusion status and prompt self-reporting obligations.

Retention periods and privacy

• Retain screening records for at least six years; many organizations retain seven to ten years to align with broader audit and litigation horizons.
• Protect PII by minimizing data collection, encrypting stored reports, and limiting access on a need-to-know basis.

Reinstatement Process for Excluded Individuals

Exclusion does not end automatically when a period lapses. The excluded person must complete the reinstatement application process with HHS OIG; until OIG grants reinstatement and the name is removed from the LEIE, the individual remains excluded for federal program purposes.

How reinstatement works

• Wait until eligible to apply, then submit the reinstatement application with required disclosures and supporting documents (e.g., licensure status, explanation of corrective actions).
• Respond to OIG requests for additional information. Processing timelines vary based on case complexity.
• Reinstatement is confirmed in writing, and removal from the LEIE is the operative indicator for screening purposes.

What employers should verify

• Confirm the individual’s removal from the LEIE before any participation in federally reimbursed work.
• Re-screen during onboarding and add the person to your monthly monitoring like any other workforce member.

Conclusion

Build a simple, reliable system: screen the LEIE (and SAM for vendors) before onboarding and monthly thereafter; verify potential matches with second identifiers; document every step; and respond quickly to problems. This approach keeps your telehealth operation aligned with federal healthcare regulations, prevents overpayments, and sustains exclusion screening compliance as you scale.

FAQs.

What is the OIG exclusion screening requirement for telehealth companies?

You must avoid employing or contracting with individuals or entities that are excluded from federal health care programs for any work that contributes to federally reimbursed items or services. Practically, that means screening your workforce and key vendors against the LEIE (and, as a best practice, SAM) and removing any confirmed matches from federally billable activities.

How often should telehealth companies perform exclusion screenings?

Screen at onboarding and then monthly. Apply the same cadence to high-risk vendors and contractors, and perform ad hoc rechecks when events occur (name or license changes, role transitions, reactivations, or adverse actions).

What are the penalties for hiring excluded individuals?

Consequences include civil monetary penalties, repayment of tainted claims as overpayments, potential False Claims Act exposure, and contract or program participation risks. You may also face audits, recoupments, and reputational damage.

How can excluded individuals apply for reinstatement?

They must submit a reinstatement application to HHS OIG. Reinstatement is not automatic; OIG reviews the submission and, if approved, confirms in writing and removes the individual from the LEIE. Employers should verify LEIE removal before allowing any federally reimbursed work.