Free template · Built on OIG and CMS guidance
Exclusion screening policy generator
Auditors, payers and managed care plans ask two things: do you have a screening policy, and can you prove you follow it. Fill in your practice and states to get a clear written policy you can adopt today.
Your practice details
[Practice name]: Exclusion Screening Policy
1. Purpose
[Practice name] does not employ, contract with or bill for items or services furnished, ordered or prescribed by any person or business excluded from federal health care programs or from a state Medicaid program. This policy sets out how we check that, how often, and what we do if we find a match.
2. Who is screened
We screen these people and businesses:
- all employees, full-time, part-time and temporary
- independent contractors and locum tenens
- vendors and their staff who furnish items or services that federal health care programs pay for, directly or indirectly (for example billing companies, staffing agencies, laboratories and suppliers)
- owners, officers and board members
3. Lists we check
Each screening covers:
- HHS Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE)
- SAM.gov federal exclusions
- [The Medicaid exclusion list of each state where we bill Medicaid]
4. When we screen
- Before anyone starts work or a contract is signed, including any former names they have used.
- Every month, on or after the 15th, after OIG publishes its monthly LEIE update.
- Whenever someone changes their name, and when a state list we rely on publishes a new edition.
5. How we screen
- We search by full legal name and any former names, not by NPI alone, because most people on the LEIE have no NPI listed.
- Businesses are screened by legal name and any trade name.
- Vendors and staffing agencies give us their screening records each quarter, or we screen their staff ourselves. Responsibility stays with us.
6. If there is a possible match
- The compliance contact compares date of birth, address, license and specialty with our records. A name match alone is not proof, and the review is kept confidential.
- For OIG, the match is confirmed or ruled out by entering the Social Security number or EIN in OIG’s online search. For SAM.gov and state lists, we compare identifiers and contact the publishing agency if needed.
- If confirmed, the person is removed from any work paid for directly or indirectly by federal health care programs the same day, and we hold claims for items or services they furnished, ordered or prescribed.
- We work out the period and amounts involved, take legal advice, and report and return any overpayment within 60 days of identifying it, or use OIG’s Self-Disclosure Protocol or the state’s self-disclosure process as advised.
7. Records
For every screening we keep the date, who ran it, the lists and list dates used, the names checked, the result and any follow-up. Records are kept for at least 6 years.
8. Responsibility
[Compliance contact] owns this policy, runs or oversees each screening, and reports results to practice leadership. Employees and contractors must tell [Compliance contact] at once if they are excluded, proposed for exclusion or sanctioned by any program or licensing board.
9. Review
This policy takes effect on 2026-10-26 and is reviewed at least once a year.
A starting template based on OIG and CMS guidance, not legal advice. Have your compliance adviser review it before you adopt it. Nothing you type is sent to us.
What a good screening policy covers
The template follows the points OIG’s 2013 Special Advisory Bulletin makes about exclusion and the monthly expectation CMS set for Medicaid providers in State Medicaid Director Letter #09-001:
- Who is screened. Not just clinicians. OIG’s payment ban reaches billing, management and other administrative work at a practice that bills federal programs, and contractors and vendors whose work is paid for directly or indirectly.
- Which lists. OIG’s LEIE, SAM.gov and the Medicaid list of every state where you bill. Our state directory has every state’s official list.
- When. Before hire and every month, after OIG’s monthly update.
- How a match is handled. Confirm with the SSN on OIG’s site, stop federally reimbursed work, quantify, and report and return overpayments within 60 days or self-disclose on legal advice.
- Records and ownership. A named owner and dated records kept long enough to cover the six-year period in which OIG can act.
Related
Estimate what a missed exclusion would cost with the excluded employee cost calculator, read the OIG exclusion screening guide, or follow the response plan if a match is confirmed.
- 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
Is a written screening policy required?
No federal statute requires a private practice to have one. But OIG recommends monthly screening, many state Medicaid programs require providers to screen employees and contractors monthly, and managed care contracts often ask for proof. A written policy plus dated records is how you show it is done.
Which states should the policy list?
Every state where you bill Medicaid, and often the states where staff and contractors have lived or worked. The generator fills in each state’s official list name, or notes when a state has no public list.
Why monthly?
OIG updates its list monthly and says monthly screening best minimizes overpayment and penalty liability. CMS’s 2009 letter to state Medicaid directors told states to require providers to search monthly.
Why six years of records?
The civil monetary penalties law lets OIG act up to six years after a claim was presented, and New York’s OMIG uses a six-year lookback. Keeping records at least that long covers the window anyone could ask about.
Does the policy cover vendors?
It can, and it should if their work is paid for directly or indirectly by federal programs. OIG says the provider is liable for overpayments for items or services furnished by an excluded person, whoever did the screening.
Sources
- HHS OIG, Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (May 8, 2013) — scope of who to screen, monthly screening, contractor and vendor liability
- CMS, State Medicaid Director Letter #09-001 (January 16, 2009): providers should search for excluded employees and contractors monthly — state Medicaid requirement for providers to screen monthly
- HHS OIG, Exclusions database help — confirming a match with an SSN or EIN
- HHS OIG, Health Care Fraud Self-Disclosure Protocol (issued April 17, 2013, amended November 8, 2021) — self-disclosure route
- Foley & Lardner, CMS final regulations on the 60-day overpayment refund rule (effective January 1, 2025) — the 60-day overpayment rule
- 42 U.S.C. § 1320a-7a(a), civil monetary penalties (Cornell LII) — the six-year limit behind the records period
This template is general information, not legal advice. Adapt it to your practice and have it reviewed before adopting it.