How to Perform OIG Exclusion Screening for Hospice Providers: LEIE Requirements, Frequency, and Best Practices

OIG Exclusion Screening Overview

OIG exclusion screening protects Medicare and Medicaid from fraud and abuse by ensuring you do not employ or contract with individuals or entities barred from federal healthcare programs. For hospices, this is integral to Federal Healthcare Program Screening and a core compliance control.

The Office of Inspector General (OIG) maintains the List of Excluded Individuals/Entities (LEIE). If you pay, bill, or delegate patient-facing or claims-impacting tasks to an excluded person, related claims can be treated as Medicare Exclusion or Medicaid overpayments, triggering recoupment and potential penalties.

Screening must extend beyond employees to medical directors, referring clinicians under agreement, contractors, volunteers in patient care roles, owners, and key vendors whose services flow to federal claims. Effective Exclusion Screening Policies set scope, cadence, and accountability so nothing falls through the cracks.

LEIE Database Description

The LEIE is the OIG’s authoritative database identifying individuals and organizations excluded from participation in federal healthcare programs. It records names and known aliases, unique identifiers (such as NPI or EIN when available), exclusion authority, and effective dates, plus limited reinstatement data.

You can search the LEIE online by name or download monthly files for batch screening. Because spelling variations and name changes are common, you should search multiple permutations and confirm potential matches using secondary data points (date of birth, NPI/EIN, address) before taking action.

LEIE status focuses on federal program participation. State Medicaid Program Integrity units may also maintain separate exclusion or termination lists; align your screening to payer and state requirements to ensure complete coverage.

Screening Frequency Guidelines

Adopt a “before and ongoing” model: screen pre-hire or pre-contract, then re-screen at a defined cadence. Monthly LEIE checks are widely considered the industry standard because the database updates monthly and many payers and states expect monthly Medicaid Program Integrity screening.

Layer frequency by risk: monthly for anyone tied to patient care, ordering, coding, billing, or cost reporting; quarterly for low-risk vendors whose services never touch claims; and ad hoc re-screens after any name, ownership, or role change. Document your rationale for any deviations.

When new locations open, ownership changes, or you add new service lines, conduct a one-time catch-up to ensure all individuals and entities associated with claims have been screened under your current Exclusion Screening Policies.

Hospice Screening Process

1) Define scope and data sources

Compile a master roster of employees, contractors, volunteers in care roles, board members, owners, and high-impact vendors. Capture legal name, known aliases, date of birth (for individuals), NPI/EIN, and start dates. Sync this roster with HR, credentialing, medical staff, and accounts payable systems.

2) Pre-engagement screening

Screen candidates, contractors, and vendors before onboarding or first payment. Require written disclosure of prior exclusions, ownership interests, and any pending actions that could lead to exclusion.

3) Ongoing monitoring

Run monthly LEIE checks against the roster. Include name variations and former names to reduce false negatives. For entities, search legal name, DBA, and parent/subsidiary names when applicable.

4) Triage and verification

Flag potential matches, then verify using secondary identifiers (DOB, NPI/EIN) and source documents. Keep the individual or entity non-billable while you confirm. If matched, immediately remove from federal program-related duties.

5) Remediation and reporting

If you confirm an exclusion, stop claims involvement, quantify potential exposure, initiate repayment or adjustment workflows, and consult counsel about self-disclosure options. Update risk assessments and training to prevent recurrence.

6) Recordkeeping

Maintain auditable logs showing search dates, data sources, exact search strings, potential matches, verification steps, determinations, and decision-makers. Retain records per your policy and payer contract requirements.

Consequences of Non-Compliance

Submitting claims tied to excluded individuals or entities can create overpayments, trigger Civil Monetary Penalties, and result in repayment demands from Medicare and Medicaid. If conduct is deemed knowing or reckless, you risk False Claims Act Liability, including treble damages and per-claim penalties.

Additional impacts may include termination from network participation, corrective action plans, corporate integrity obligations, and reputational damage. Leadership and board oversight may also come under scrutiny if Exclusion Screening Policies are inadequate or ignored.

Best Practices for Compliance

• Adopt monthly LEIE screening for anyone who influences care, coding, billing, or cost reporting; align lower-risk vendors to a documented, risk-based cadence.
• Centralize screening under compliance, but integrate with HR onboarding, medical staff credentialing, and vendor intake so screening is automatic and timely.
• Use standardized identifiers (DOB, NPI/EIN) and maintain an alias table to catch spelling changes and hyphenations.
• Leverage automation or batch screening with human quality checks; keep clear exception queues and escalation paths.
• Obtain contractual attestations of non-exclusion from contractors and vendors, with notice and termination rights if exclusion occurs.
• Train managers and schedulers so excluded persons are never assigned to federal program-related duties.
• Periodically audit samples of searches, matches, and resolutions to validate effectiveness and completeness.

Documentation and Policy Development

Create a written policy that defines scope (who and what you screen), frequency, data sources, verification steps, remediation, reporting lines, and record retention. Reference Medicare Exclusion and Medicaid Program Integrity expectations and specify how state requirements are incorporated.

Build procedures that specify exact search fields, match thresholds, evidence for verification, and timelines for removing matched individuals from duties. Include roles and accountability: who runs the screens, who verifies, and who approves decisions.

Establish documentation standards: retain search logs, batch files, screenshots or results exports, match workups, and final determinations. Set retention aligned to payer contracts and regulatory guidance, and schedule periodic policy reviews.

Conclusion

Consistent, documented OIG exclusion screening anchored on the LEIE safeguards your hospice from overpayments, Civil Monetary Penalties, and False Claims Act exposure. By screening before engagement and monthly thereafter—and by enforcing clear, auditable Exclusion Screening Policies—you protect patients, programs, and your organization’s integrity.

FAQs

What is the LEIE and why is it important for hospice providers?

The LEIE is the OIG’s List of Excluded Individuals/Entities. It identifies people and organizations barred from federal healthcare programs. For hospices, checking the LEIE prevents billing tied to excluded participants and reduces risks of overpayments, Civil Monetary Penalties, and reputational harm.

How often should hospices perform OIG exclusion screenings?

Screen pre-hire or pre-contract and then monthly for anyone connected to patient care, ordering, documentation, coding, billing, or cost reporting. Monthly screening aligns with the LEIE’s monthly update cycle and common payer and Medicaid Program Integrity expectations.

What are the risks of employing excluded individuals?

You risk claim denials and repayment, Civil Monetary Penalties, and potential False Claims Act Liability if the conduct is deemed knowing. You may also face corrective actions, contract terminations, and damage to trust with patients, payers, and regulators.

What are the recommended best practices for exclusion screening in hospice care?

Use a written, risk-based policy; perform monthly LEIE checks; expand scope to employees, contractors, volunteers in care roles, owners, and key vendors; verify potential matches with identifiers; document searches and decisions; audit routinely; and require attestations and prompt notifications of any status changes.