Wellformed AI

Guide · Medical practices

OIG Exclusion Screening for Medical Practices: The Complete 2026 Guide

Who to check, how often, what a missed exclusion costs, and a screening routine that stands up when an auditor asks for proof.

Rules checked October 21, 2026 against HHS OIG LEIE monthly file (refreshed on every site update); CMS NPPES NPI Registry (live). Next scheduled check: November 20, 2026. See all rule updates
The short answer

Check every employee, contractor and vendor whose work is paid for directly or indirectly by Medicare, Medicaid or another federal health program against OIG’s List of Excluded Individuals and Entities (LEIE) before you hire them and every month after. Search by name, not just NPI, confirm any possible match with a Social Security number on OIG’s site, and keep a dated record of every check.

Run a free check now, or look up an NPI with the exclusion check built in.

$25,595maximum penalty per item or service after HHS’s inflation adjustment, plus up to 3 times the amount claimed.HHS inflation adjustment, 2026
$525,883paid in one August 2026 settlement for employing an excluded individual, even after self-disclosing.OIG, August 2026
Monthlyis how often OIG says screening “best minimizes” overpayment and penalty liability.OIG advisory bulletin, 2013
89%of excluded people and businesses have no NPI on the list, so NPI-only checks miss them.Our count, October 2026 file

What exclusion means

The HHS Office of Inspector General can bar people and businesses from federal health care programs after certain convictions, license actions and other conduct. Once someone is excluded, Medicare, Medicaid and other federal health programs will not pay for any item or service that person furnishes, orders or prescribes. OIG publishes everyone currently excluded in the LEIE and updates it by the 10th of each month.

The payment ban follows the person, not the job title. OIG’s 2013 Special Advisory Bulletin, still its main guidance on the subject, makes clear that it reaches far beyond doctors and nurses. If an excluded person’s work is part of what a federal program pays for, even indirectly, that payment is not allowed.

Who you must screen

OIG’s test is whether the work is directly or indirectly payable by a federal health program. For most practices that bill Medicare or Medicaid, that covers almost everyone.

GroupExamplesScreen?
Licensed cliniciansPhysicians, nurse practitioners, physician assistants, therapists, nursesYes
Clinical supportMedical assistants, aides, technicians, pharmacy staffYes
Administrative staffFront desk, billing, coding, scheduling, HRYes
LeadershipPractice manager, CFO, owners who manage operationsYes
Contracted and agency staffLocum tenens, agency nurses, outsourced billing staffYes, or verify the agency’s screening
Vendors and suppliersBilling companies, labs, equipment suppliers, IT vendors with billing rolesYes, the business and key people
Volunteers and studentsAnyone doing work tied to federally paid servicesYes
Referring and ordering providersOutside clinicians whose orders you bill onRecommended

What a missed exclusion costs

The money comes from three directions at once:

  1. Repayment. Federal programs can recover everything paid for items and services the excluded person furnished, ordered or prescribed. Overpayments must be reported and returned within 60 days of being identified.
  2. Civil money penalties. Under 42 U.S.C. § 1320a-7a, a provider that employs or contracts with someone it knew or should have known was excluded faces up to $20,000 per item or service in the statute, $25,595 after the latest inflation adjustment, plus up to three times the amount claimed.
  3. Exclusion of the practice itself. OIG may also exclude the employer, which ends its ability to bill federal programs.

Sources: 42 U.S.C. § 1320a-7a (civil monetary penalties); HHS inflation adjustment, January 2026; 42 U.S.C. § 1320a-7k(d).

2026 settlements

OIG publishes its civil money penalty settlements. These five from 2026 were all for allegedly employing someone the provider knew or should have known was excluded. Every one of them self-disclosed to OIG, and each still paid. The settlements resolve allegations; they are not findings of liability. None are Wellformed AI clients.

ProviderDatePaidRole named
Liberty County Hospital District No. 1 and PF Carthage SNF OpsAug 24, 2026$525,882.88Not stated
Advanced Health Care of Colorado SpringsJul 20, 2026$500,019.53Medication and treatment nurse (RN/LPN)
Dialysis Care CenterAug 24, 2026$254,530.09Not stated
Barnet Dulaney Perkins Eye CenterMay 8, 2026$175,513.11Not stated
Cookeville Regional Medical CenterJun 26, 2026$20,000.00Not stated

Who is on the list

These charts are drawn from OIG’s current monthly file, the same data our free check uses, and they update when OIG publishes each new list.

Loading OIG’s latest list…

In OIG’s October 2026 file, the most common ground for exclusion was license revocation, suspension or surrender (33,455 entries), and 43,838 of the 84,093 exclusions were mandatory. OIG’s “Nursing profession” category alone held 12,576 entries and “Employee, private sector” 5,421, against 3,277 in “Physician (MD, DO)”. Screening only your doctors misses most of the list. So does screening by NPI: most entries have none, and name searches are the only way to catch them.

Mandatory and permissive exclusions

OIG excludes under two kinds of authority in section 1128 of the Social Security Act. The difference matters when you read a match, because it tells you why the person was excluded and how long it lasts at a minimum.

TypeCommon groundsMinimum length
MandatoryConviction of a program-related crime, patient abuse or neglect, felony health care fraud, felony controlled-substance conviction5 years; 10 years for a second offense; permanent for a third
PermissiveLicense revocation or surrender, misdemeanor fraud, exclusion by another program, kickbacks, defaulting on health education loans, and othersVaries: from no minimum to the period set by the licensing board or program

Our exclusion check shows the plain-English meaning of the authority on every match. Source: HHS OIG, Background Information and Exclusion Authorities.

How often to screen

No statute or regulation tells a private practice how often to check. OIG’s bulletin recommends checking before you hire or contract with someone and periodically after, and says screening every month “best minimizes” the risk of overpayments and penalties, because the list itself changes monthly.

Medicaid sets a firmer example. Federal rules require state Medicaid agencies to check the LEIE and the federal exclusion system in SAM at least monthly for the providers they enroll, and many states pass that expectation on to providers through their agreements. Source: 42 CFR § 455.436.

The lists that matter

ListRun byWhat it coversHow to confirm a match
LEIEHHS OIGExclusions from federal health care programsSSN or EIN on OIG’s online search
SAM.gov exclusionsUS General Services AdministrationDebarments and exclusions across federal agencies, including some health program exclusionsRecord details on SAM.gov
State Medicaid exclusion listsEach state Medicaid programPeople and businesses barred from that state’s Medicaid program, which may not be on the LEIEVaries by state
State licensing boardsEach state boardLicense status, discipline and restrictionsThe board’s own lookup
NPI RegistryCMSProvider identity and NPI status, self-reportedNPI number

A screening process that holds up

Monthly screening routine
  1. Keep a roster. Every employee, contractor, volunteer and vendor, with legal name, any former names, date of birth, NPI if any, and start date.
  2. Collect identifiers securely. You will need a Social Security number (or a business’s EIN) only to confirm a possible match on OIG’s site. Store it with your HR records, not in screening spreadsheets.
  3. Screen before day one. Check new hires and new vendors before they start any federally reimbursed work.
  4. Search by name, then NPI. Name searches catch the 89% of entries without an NPI. Search former names and business names too.
  5. Repeat monthly. After OIG publishes the new list, check everyone on the roster again.
  6. Save dated proof. Print or save each result as a PDF showing who was checked, which list month and the result.
  7. Put it in contracts. Require vendors and staffing agencies to screen their people and share records on request.
Free tool
Check a person or business by name against OIG’s current list, with a dated record to save.
Run a free check

How to read an LEIE entry

OIG publishes the list in two forms: an online search, and a downloadable file that tools like ours use. The downloadable file has one row per excluded person or business with these fields, and knowing them makes a possible match much faster to judge:

FieldWhat it tells youHow to use it
Last, first and middle nameThe individual’s name as OIG recorded itCompare with legal and former names on your roster
Business nameFilled in for excluded entitiesSearch vendors and the businesses your staff own
General and specialtyOIG’s category and the person’s field, such as nursing or a business typeDoes it fit the person you hired?
NPIPresent on only a minority of entriesAn NPI match is strong evidence; no NPI proves nothing
Date of birthIncluded for many individualsA quick way to rule a match in or out
Address, city and stateThe address at the time of exclusionOlder entries may show an old address
Exclusion typeThe section of the Social Security Act usedTells you why and whether it was mandatory
Exclusion dateWhen the exclusion took effectClaims after this date are the ones at risk
Waiver date and stateA narrow waiver, if one was grantedCovers only the state or program named

The file does not include Social Security numbers or EINs. That is deliberate: it lets anyone screen without exposing identity numbers, and it is why OIG asks you to confirm a possible match by entering the SSN or EIN on its own online search, which checks it against the full record. Source: HHS OIG, Exclusions database help.

What a good screening record shows

If an auditor, payer or OIG asks, you want to show not just that you screened but how. A record that holds up answers six questions for every check:

  1. Who was checked: the full legal name and any other names searched.
  2. When: the date and time of the check.
  3. Against what: which list and which month’s version. Our tool prints the date of OIG’s file it used.
  4. What was found: no match, or the possible matches and how each was resolved.
  5. Who ran it: the staff member responsible.
  6. What happened next: for a confirmed match, the actions taken and when.

Keep these records with your compliance files, not loose in email. A simple folder per month with one PDF per check, or one combined report, is enough. If you outsource screening, ask for the same information in the vendor’s reports.

If you find a possible match

Most name matches are different people with the same name. Handle a possible match carefully and in this order:

  1. Don’t act on a name alone. Compare city, state, date of birth year and specialty from the match with your records.
  2. Verify on OIG’s site. Enter the person’s SSN or the business’s EIN in OIG’s online search to confirm or rule out the match.
  3. If confirmed, stop federally reimbursed work at once. Remove the person from any role tied to federal program payment and stop billing for their services.
  4. Work out what was paid. Identify claims tied to the person’s work since the exclusion date. Overpayments must be returned within 60 days of being identified.
  5. Take legal advice and consider self-disclosure. OIG’s Self-Disclosure Protocol is the route OIG points providers to for resolving liability.
  6. Document everything. Dates you checked, what you found, and what you did.

Reinstatement and waivers

An exclusion does not end on its own. When the period is over, the person must apply to OIG for reinstatement, and they remain on the LEIE until OIG approves it. Once reinstated, they are removed from the current list. That is why someone excluded years ago can still appear today.

Some entries also show a waiver, which allows a specific provider to keep serving patients in a particular state or program, usually where access to care would otherwise suffer. A waiver is narrow: it covers only what it names. Our check shows waiver details when OIG lists them.

Ten common mistakes

  1. Screening only clinicians. Billing and administrative staff count.
  2. Checking once at hire. People are excluded after they join you.
  3. Searching only by NPI. Most entries don’t have one.
  4. Ignoring former names. People can be listed under a maiden or previous name.
  5. Trusting a vendor without proof. OIG says liability stays with you.
  6. Firing on a name match. Confirm with the SSN first.
  7. Keeping no records. An undocumented check is hard to prove.
  8. Checking only the LEIE. SAM.gov and state Medicaid lists can differ.
  9. Assuming exclusions expire. Reinstatement requires an application.
  10. Waiting to repay. The 60-day clock starts when an overpayment is identified.

Pro tips

What isn’t settled

Questions

Is OIG exclusion screening required by law?

No statute or regulation requires a private practice to screen. But federal programs won’t pay for anything an excluded person furnishes, and you can be fined if you knew or should have known someone was excluded. OIG says monthly screening best minimizes that risk, so in practice it is expected.

How often should we check the OIG list?

Before hiring or contracting, and then monthly. OIG updates the list by the 10th of each month, and its advisory bulletin says monthly screening “best minimizes” overpayment and penalty risk.

Do front-desk and billing staff need to be checked?

Yes. OIG’s bulletin covers administrative and management work paid for directly or indirectly by federal programs, including billing, accounting, HR and leadership roles.

What is the fine for employing an excluded person?

The statute sets up to $20,000 per item or service, plus up to three times the amount claimed. After HHS’s inflation adjustment published in January 2026, the maximum is $25,595 per item or service. OIG can also exclude the employer.

Can we hire an excluded person at all?

Only in limited cases, for work that no federal health program pays for, directly or indirectly. OIG warns that this is narrow for any provider that bills federal programs.

Is a name match proof that someone is excluded?

No. Many people share names. Confirm a possible match with the person’s Social Security number (or a business’s EIN) on OIG’s own online search before taking action.

Do we need to check SAM.gov too?

Many payers and state Medicaid programs expect it. State Medicaid agencies themselves must check both the LEIE and SAM at least monthly, and many pass that expectation on to providers in their agreements.

Does an exclusion end automatically?

No. When the period ends, the person must apply to OIG for reinstatement and stays on the list until OIG approves it.

Can we rely on our staffing agency’s screening?

You may, but OIG recommends verifying it, for example by asking for screening records. Liability stays with you.

What should we do if a current employee turns out to be excluded?

Remove them from any federally reimbursed work at once, stop billing for their services, work out what was paid, take legal advice and consider OIG’s Self-Disclosure Protocol. Overpayments must be reported and returned within 60 days of being identified.

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Sources

Each link opens the original in a new tab.

  1. HHS OIG, Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (May 8, 2013) — what exclusion covers, who to screen, monthly screening recommendation, contractor screening, self-disclosure
  2. 42 U.S.C. § 1320a-7a (civil monetary penalties) — the civil monetary penalty for employing or contracting with an excluded person
  3. Federal Register, Annual Civil Monetary Penalties Inflation Adjustment (HHS, January 28, 2026) — the inflation-adjusted penalty amount in force in 2026
  4. HHS OIG, Background Information and Exclusion Authorities — exclusion authorities, mandatory and permissive exclusions and minimum periods
  5. HHS OIG, LEIE downloadable database — the monthly LEIE file our tool and charts are built from
  6. HHS OIG, Exclusions database help — monthly update timing and verifying a match with an SSN or EIN
  7. 42 CFR § 455.436, State Medicaid database checks (Cornell LII) — monthly LEIE and SAM checks by state Medicaid agencies
  8. 42 U.S.C. § 1320a-7k(d), reporting and returning overpayments (Cornell LII) — the 60-day rule for reporting and returning overpayments
  9. Faegre Drinker, HHS-OIG updates its Self-Disclosure Protocol (November 2021) — Self-Disclosure Protocol minimum settlement and multiplier
  10. SAM.gov, Entity information and exclusions search — the federal exclusions search
  11. CMS NPPES NPI Registry — NPI lookups
  12. OIG, Liberty County Hospital District No. 1 and PF Carthage SNF Ops agreed to pay $525,000 (August 2026) — settlement amount and date
  13. OIG, Advanced Health Care of Colorado Springs agreed to pay $500,000 (July 2026) — settlement amount and date
  14. OIG, Dialysis Care Center agreed to pay $254,000 (August 2026) — settlement amount and date
  15. OIG, Barnet Dulaney Perkins Eye Center agreed to pay $175,000 (May 2026) — settlement amount and date
  16. OIG, Cookeville Regional Medical Center agreed to pay $20,000 (June 2026) — settlement amount and date

This guide gives general information, not legal or compliance advice. Confirm any possible exclusion match on OIG’s website and take legal advice before acting on a confirmed match. Last checked October 21, 2026.