OIG Exclusion Screening Checklist: Step-by-Step LEIE Compliance

Use this practical checklist to build a defensible OIG exclusion screening program that satisfies the List of Excluded Individuals/Entities (LEIE) requirements. You will learn how to access the data, run searches, verify identities, document results, set the right cadence, and respond to potential matches.

The guidance below focuses on federal health care program exclusions and is written to help compliance, HR, credentialing, supply chain, and revenue cycle teams work from one clear, auditable process.

OIG Exclusion Screening Requirement

You must not employ or contract with any individual or entity that appears on the OIG’s List of Excluded Individuals/Entities to furnish items or services payable by Medicare, Medicaid, or any other federal health care program. Screening ensures you identify exclusions before work is performed or claims are submitted.

• Scope: employees, licensed independent practitioners, temps, volunteers in patient-care roles, owners, officers, board members where applicable, contractors, and downstream vendors.
• Objective: prevent billing for services furnished, ordered, or prescribed by excluded parties and avoid associated overpayments and civil monetary penalties.
• Core control: systematic LEIE screening with clear rules for identity verification, documentation, and escalation.

LEIE Access Methods

Choose one or more access methods that fit your volume, systems, and staffing model.

• Online LEIE Search: ad hoc lookups for individuals or entities; use for point-in-time verifications and small volumes.
• Downloadable LEIE Database: bulk screening against your roster; schedule monthly pulls and maintain a versioned archive.
• Third-Party Screening Tools: automate matching, alias handling, and monitoring; still validate results and keep internal audit controls.
• Complementary Checks: consider System for Award Management screening for federal contracting risk in addition to LEIE.

Search Process

1. Assemble your roster: legal name, known aliases/maiden names/DBAs, date of birth for people, address, NPI if applicable, and—when lawful and available—the last four digits for Social Security Number verification or Employer Identification Number verification.
2. Normalize names: remove punctuation, expand hyphens, and standardize prefixes/suffixes to improve matching.
3. Run exact and variant searches: search legal name, common nicknames, prior names, and DBAs to capture near matches.
4. Capture potential matches: export or record all candidate records; do not dismiss similar spellings until verified.
5. Escalate to identity verification: move any “possible” match to a structured verification workflow before making a final determination.
6. Log everything: record the date/time, data version, search terms, and results as part of your audit trail documentation.

Identity Verification

Confirm whether a candidate match is your person or entity using objective identifiers and documented procedures.

• Individuals: compare full name, aliases, date of birth, professional license number, NPI, and—when permissible—last four SSN for Social Security Number verification.
• Entities: compare legal name, DBA, address, NPI (if any), and last four EIN for Employer Identification Number verification.
• Resolve discrepancies: request source documents (e.g., driver’s license, W-9, license verification) and involve HR/credentialing as needed.
• Decision record: document evidence reviewed, the final determination (match/no match), approver, and date.

Documentation Practices

Strong records prove your controls worked and make audits straightforward.

• Audit trail documentation: data source and version/date, names and identifiers searched, search parameters used, results returned, and who performed the screening.
• Artifacts: saved exports, screenshots, or match reports; attach verification evidence for each potential match.
• Retention and security: follow your record retention policy and protect PII/PHI with access controls and minimum-necessary handling.
• Governance: maintain a written SOP, role assignments, training records, and quality checks (spot audits, exception reviews).

Frequency of Screening

Set a cadence that prevents excluded parties from participating in reimbursable services and detects changes quickly.

• Pre-engagement: screen at hiring, appointment, onboarding, or contract execution—before any federal program work.
• Routine monitoring: conduct monthly LEIE screening for all in-scope individuals and entities.
• Event-driven checks: re-screen upon name changes, role changes, credentialing/privileging updates, or new subcontractors.
• Mergers and acquisitions: screen all acquired personnel and vendors during diligence and post-close integration.

Actions Upon Match

Respond decisively to reduce financial, operational, and legal exposure.

• Immediate containment: remove the individual/entity from federal health care program activities and pause related billing.
• Confirm identity: finalize verification using DOB, license/NPI, and last four SSN/EIN; document the determination.
• Assess impact: identify dates of service, affected claims, and any overpayments tied to the excluded party.
• Remediate and disclose as appropriate: consult counsel on repayment, potential disclosures, contract actions, and corrective measures.
• Prevent recurrence: update screening criteria, training, and monitoring; perform a targeted re-screen of similar names.
• Recordkeeping: keep a complete file of findings, decisions, communications, repayments, and corrective actions.

Effective LEIE compliance hinges on clear ownership, reliable data access, disciplined monthly screening, rigorous identity verification, and well-kept records—so you can demonstrate control and avoid civil monetary penalties.

FAQs.

What is the OIG exclusion screening requirement?

You must screen your workforce and relevant contractors against the OIG’s LEIE to ensure excluded individuals or entities do not furnish, order, or bill for items or services payable by federal health care programs. If an excluded party is involved, related claims are at risk and must be addressed.

How often should LEIE screening be conducted?

Screen before engagement and then monthly for everyone in scope. Monthly screening helps you catch new exclusions quickly and demonstrate continuous oversight.

What steps should be taken if a match is found?

Immediately remove the person or entity from federal program work, confirm identity using objective identifiers, quantify and resolve any overpayments, consider appropriate disclosures or repayments with counsel, implement corrective actions, and document the entire process.

What are the consequences of non-compliance?

Submitting claims tied to excluded parties can trigger repayments, civil monetary penalties, potential False Claims Act exposure, contract or network termination, and reputational harm. Robust screening, verification, and documentation substantially reduce these risks.