Free calculator · OIG’s published method · Checked October 26, 2026
What does an excluded employee cost your practice?
If someone on the OIG exclusion list worked for you, federal programs treat what they touched as unpayable. This calculator estimates the bill the way OIG does, from pay, months and payor mix, so you can see the risk before it happens.
What one excluded hire could cost
Staff whose work is part of your services but not billed separately: aides, nurses, billers, front desk, managers. OIG values their work at what you paid to employ them during the exclusion, times your share of revenue from federal health care programs.
If you self-disclose to OIG, expect to pay at least $29,402: 1.5 times the $19,601 federal share. OIG can apply a higher multiplier. That is about 31 years of monthly screening at $948 a year.
The longer it goes unnoticed, the more it costs
Estimated self-disclosure settlement by how long the person worked before you found out. Monthly screening keeps the gap to about a month.
Estimates use OIG’s published method (Self-Disclosure Protocol, amended 2021): total cost of employment during the exclusion × federal payor mix, a 1.5× minimum multiplier and a $20,000 minimum settlement. The legal maximum is $25,595 per item or service (HHS adjustment, January 2026) plus up to 3× the amount claimed. Example pay figures are 2025 national medians from the BLS Occupational Outlook Handbook; benefits default to 43% of pay (BLS, June 2026). Repayment of overpayments, state Medicaid action and legal costs are separate. This is information, not legal advice.
How the estimate works
OIG publishes how it values these cases in its Health Care Fraud Self-Disclosure Protocol (issued 2013, amended November 8, 2021). There are two methods, and the calculator’s two buttons match them.
- Work that isn’t billed on its own. For an aide, nurse, biller, front-desk worker or manager, OIG uses your total cost of employing or contracting with the person during the exclusion (salary, benefits and anything else of value) and multiplies it by your revenue-based federal health care program payor mix.
- Services billed under their name. For a clinician whose own services appear on claims, the disclosure lists the amounts claimed and paid by each federal program for what they furnished, ordered or prescribed.
That gives single damages. OIG then generally applies a multiplier of at least 1.5 to self-disclosed matters and requires a minimum settlement of $20,000. If OIG finds the problem instead of you, the ceiling is far higher: up to $25,595 for each item or service, plus up to three times the amount claimed (42 U.S.C. § 1320a-7a).
A worked example
A medical assistant paid the 2025 national median of $45,690 (BLS) works 8 months before anyone notices they were excluded. Benefits and payroll taxes add 43% (BLS, June 2026), and 45% of the practice’s revenue comes from federal programs.
| Pay for 8 months | $45,690 × 8/12 = $30,460 |
|---|---|
| Plus benefits and taxes (43%) | $43,558 |
| × federal payor mix (45%) | $19,601 single damages |
| × 1.5 minimum multiplier | $29,402 likely settlement |
That is before any overpayment refunds to Medicaid, the cost of a lawyer, and the staff time to rebuild the record. The same practice pays $948 a year for monthly monitoring.
Why monthly screening is the cheapest fix
The bill grows with every month the person keeps working. For the same medical assistant:
| Found after | Single damages | Likely settlement |
|---|---|---|
| 1 month | $2,450 | $20,000 |
| 3 months | $7,350 | $20,000 |
| 6 months | $14,701 | $22,051 |
| 12 months | $29,402 | $44,102 |
| 24 months | $58,803 | $88,205 |
Below about six months the $20,000 minimum sets the price, so catching it fast mostly protects you from the larger numbers. OIG updates its list every month and recommends checking employees and contractors monthly (OIG advisory bulletin, 2013). A yearly check leaves up to twelve months of exposure; a monthly one leaves about one.
If this already happened
Confirm the match with the person’s Social Security number on OIG’s own search before doing anything else; most name matches are different people. If it is confirmed, stop their federally reimbursed work, work out the dates, and talk to a health care attorney about refunding overpayments or using OIG’s Self-Disclosure Protocol. Our step-by-step response plan for an excluded employee walks through each decision, and the screening guide lists 2026 settlements.
Check your team now
Run a free check of one person on the OIG, SAM.gov and state Medicaid exclusion check, or your whole staff and vendor list at once with the bulk exclusion check. Both save a dated PDF record.
- Your staff, contractors and vendors saved once (up to 250 names)
- Re-screened every month against the OIG list, SAM.gov and the Medicaid lists of 16 states
- An email the day a run finds a new possible match, with the record details
- A dated PDF screening record emailed every month, ready for audits and credentialing
- Unlimited on-demand checks of your saved list, any time
Save your list once. We re-check it every month after OIG’s update and email you the dated PDF record. Cancel any time.
Start Practice ProHow it worksQuestions
Does it matter if the excluded person never billed anything?
Yes, it still matters. OIG’s 2013 advisory bulletin says the payment ban covers administrative and management services even when they are not separately billable, and its Self-Disclosure Protocol values that work at the full cost of employing the person during the exclusion, times your federal program payor mix.
What payor mix should I use?
OIG asks for your revenue-based federal health care program payor mix: the share of your revenue from Medicare, Medicaid and other federal programs, calculated separately for each program in a real disclosure. Use the share for the period the person worked.
Why is the minimum $20,000 even for one month?
Since the 2021 update of OIG’s Self-Disclosure Protocol, OIG requires a minimum settlement of $20,000 for matters that are not kickback-related. A short exclusion still costs at least that if you resolve it through self-disclosure.
Is self-disclosure always cheaper?
It usually lowers the multiplier compared with an OIG investigation, and OIG generally applies at least 1.5 times single damages for self-disclosed matters. It does not remove the cost. Whether to self-disclose, and to whom, is a decision to make with a health care attorney.
What is the most OIG can impose?
Up to $25,595 per item or service furnished by the excluded person (the inflation-adjusted amount HHS published on January 28, 2026), plus an assessment of up to three times the amount claimed, and possible exclusion of the practice itself.
Does state Medicaid add to this?
It can. State Medicaid programs recover their own overpayments. New York’s OMIG, for example, lists finding an employee on an exclusion list as a matter that needs a full self-disclosure, with a six-year lookback.
How far back can OIG go?
The civil monetary penalties law allows OIG to start an action up to six years after the claim was presented (42 U.S.C. § 1320a-7a(c)(1)).
Sources
- HHS OIG, Health Care Fraud Self-Disclosure Protocol (issued April 17, 2013, amended November 8, 2021) — how OIG values excluded-person disclosures, the 1.5× multiplier and the $20,000 minimum
- HHS OIG, Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (May 8, 2013) — the payment ban, including services that are not separately billed
- 42 U.S.C. § 1320a-7a(a), civil monetary penalties (Cornell LII) — the penalty, the 3× assessment and the six-year limit
- HHS, Annual Civil Monetary Penalties Inflation Adjustment, Federal Register, January 28, 2026 (employing or contracting with an excluded individual: $25,595) — the $25,595 inflation-adjusted maximum per item or service
- U.S. Bureau of Labor Statistics, compensation costs for private industry workers, June 2026 — benefits as a share of pay (default 43%)
- U.S. Bureau of Labor Statistics, Occupational Outlook Handbook: healthcare occupations, 2025 median pay — example pay for medical assistants, LPNs, RNs and medical records specialists
- NY OMIG, Self-Disclosure Frequently Asked Questions — an example of a state Medicaid self-disclosure rule
This calculator gives an estimate based on OIG’s published method. It is information, not legal advice; actual settlements depend on the facts, OIG’s judgment and any state Medicaid action.