How to Document OIG Exclusion Screening: Step-by-Step Guide, Logs, and Templates

OIG Exclusion Screening Requirements

OIG exclusion screening prevents payments to or on behalf of individuals or entities barred from federal healthcare program participation. You must be able to prove that screening occurred, when it occurred, what sources were checked, and how results were resolved.

At a minimum, document screening against the OIG List of Excluded Individuals and Entities (LEIE) and the System for Award Management (SAM) Excluded Parties List. Many organizations also check state Medicaid exclusion databases and licensing boards to strengthen controls around federal healthcare program exclusions.

Who must be screened

• Employees, medical staff, contractors, temps, volunteers, and students who furnish, bill for, or support items or services paid by federal programs.
• Vendors and referral sources that touch federally reimbursed services or data.

What must be documented

• Roster at the time of screening, sources queried (LEIE, SAM), search parameters, and date/time stamps.
• Results for each person/entity and exclusion match resolution documentation for any potential matches.
• Approval or sign-off showing compliance oversight.

Screening Frequency and Schedule

Perform screening at onboarding and prior to any federal program participation. Thereafter, screen on a recurring cadence—monthly is the prevailing best practice—so gaps are quickly detected and contained.

Practical scheduling model

• Pre-employment/credentialing: LEIE and SAM checks before start date or credentialing approval.
• Monthly roster sweep: Full roster screening within the same seven-day window each month.
• Event-driven checks: Immediately after name changes, new affiliates, or role changes expanding federal program exposure.

Controls that keep you on schedule

• Automated calendar reminders and workflow tasks assigned to a primary and a backup screener.
• Centralized screening log with status, due dates, and attestation fields.
• Exception reporting for missed or late screenings and remediation tracking.

Screening Process Steps

Use a consistent, auditable process. The following steps balance thoroughness with efficient documentation.

1) Prepare a clean roster

• Standardize legal name, known aliases, DOB, NPI (if any), role, location, and last four of SSN (if collected).
• De-duplicate entries; map each person/entity to a unique internal ID.

2) Query required sources

• Search the LEIE using exact and fuzzy matches; capture the query method and version/date of the data.
• Search the SAM Excluded Parties List; record the search scope (individual, entity, DUNS/UEI if used) and date.
• If applicable, query state Medicaid exclusion lists and relevant licensing boards.

3) Record screening evidence

• For each search, save date/time, screener name, data source, search terms, and the raw results or screenshots.
• Log a discrete pass/fail/no-result outcome per source for every person/entity.

4) Triage possible matches

• Flag same/similar names as “potential match.” Do not assume clearance until identifiers are compared.
• Escalate cases with partial identifier overlap for secondary review.

5) Finalize and attest

• Close out each record as “cleared,” “confirmed exclusion,” or “not applicable,” with notes.
• Capture supervisor or compliance officer attestation for the monthly batch.

Resolving and Documenting Positive Matches

When a potential hit appears, your documentation must show how you verified or ruled it out. Clear, timely exclusion match resolution documentation is essential for screening compliance audits.

Identity verification workflow

• Compare multiple identifiers: full legal name, aliases, DOB, address, NPI, license number, UEI/DUNS.
• Review exclusion details: program, effective date, and reinstatement status where available.
• Contact the individual/vendor only for permissible, minimal additional data needed to confirm identity.

If the match is confirmed

• Immediately remove the person/entity from any federal healthcare program duties or billing pathways.
• Create a case file including timeline, participants, communications, corrective actions, and risk assessment.
• Document repayment/claim hold decisions, notifications, and leadership sign-off.

If the match is ruled out

• Record the comparison logic and the evidence that led to the negative determination.
• Include screenshots or result exports, plus reviewer and approval signatures.

Maintaining Screening Documentation

Strong documentation proves consistent execution and speeds investigations. Treat screening evidence retention like any other regulated record set.

Core elements to retain

• Source evidence: LEIE and SAM search results, exports, or screenshots with timestamps.
• Process evidence: procedures, checklists, and task attestations showing how screening was performed.
• Case evidence: full files for all positive or potential matches, including final decisions.

Data integrity and access control

• Use version-controlled procedures and locked logs with role-based permissions.
• Preserve immutable evidence (PDFs or hashed exports); maintain audit trails of edits and approvals.

Quality assurance

• Quarterly spot-checks comparing roster to payroll/HRIS/credentialing to confirm completeness.
• Independent review of a sample of cleared “name-only” matches to validate resolution rigor.

Using Screening Logs and Templates

Standardized exclusion screening logs and forms make results comparable month to month and reduce gaps.

Monthly screening log (fields)

• Batch month and coverage dates; screener; approver; sources used (LEIE, SAM, state lists).
• Roster size; number screened; late/omitted records; exceptions and remediation status.
• Attestation statement with date/time and signature/initials.

Individual record template (fields)

• Internal ID; legal name; aliases; DOB; role; department; location; NPI/license (if applicable).
• LEIE search date/terms/outcome; SAM search date/terms/outcome; state search outcomes.
• Notes and attachments list (screenshots, exports).

Positive match resolution form (fields)

• Match details: source, matched name, exclusion category, effective date.
• Identifiers compared and evidence collected; determination (confirmed vs. ruled out); rationale.
• Immediate actions taken; leadership approvals; follow-up tasks and due dates.

File naming and organization

• Use consistent names: YYYY-MM_ScreeningLog.pdf; EmpID_LastFirst_LEIE_SAM_YYYY-MM.pdf.
• Maintain a folder structure by year and month with restricted, auditable access.

Retention Policies and Compliance

Define how long you will keep screening records, where they are stored, and who can access them. Clear rules support screening evidence retention and readiness for screening compliance audits.

Suggested retention time frames

• Keep routine screening logs and evidence for at least six years; many organizations retain seven to ten years.
• Preserve positive-match case files, corrective actions, and repayments for the longer of your standard retention or the close of any investigation or audit.

Governance and audit readiness

• Adopt written policies covering scope, frequency, documentation standards, and escalation paths.
• Track KPIs: monthly completion rate, average match resolution time, and exception closure rate.
• Conduct periodic mock audits to verify end-to-end traceability from roster to evidence.

Conclusion

By screening against the LEIE and the SAM Excluded Parties List on a dependable schedule, documenting each step, and retaining clear evidence, you create a defensible program. Consistent logs, robust match resolution files, and disciplined retention keep you compliant and audit-ready.

FAQs.

What information must be documented during OIG exclusion screening?

Document the roster at the time of screening, the sources checked (LEIE, SAM, and any state lists), search parameters and dates, raw results or screenshots, the determination for each person/entity, and approvals. For potential hits, include the identifiers compared, your analysis, the final decision, and any corrective actions.

How often must OIG exclusion screenings be performed?

Screen at onboarding or before engagement and then on a recurring basis—monthly is widely adopted to minimize risk. Also perform event-driven checks after name changes, role changes, or new affiliations that expand federal program exposure.

How should positive matches in exclusion screenings be handled?

Immediately remove the individual/entity from federal program work, build a case file, compare multiple identifiers to confirm the match, and document every action and decision. If confirmed, record corrective steps, leadership approvals, and any repayment or notification activity; if ruled out, record the evidence and rationale.

What is the required retention period for exclusion screening records?

Maintain routine screening evidence for at least six years, with many organizations choosing seven to ten years. Keep positive-match and remediation files for the longer of your standard period or until related audits or investigations are fully closed.