You know it’s essential to screen new hires, current employees, and vendors against the OIG-LEIE and GSA-SAM Exclusion Lists, but what’s the difference, and why screen against both?
Why You Must Check Both OIG-LEIE and GSA-SAM Exclusion Lists
Federal database checks — 42 CFR Part §455.436 regulations, all State Medicaid agencies must do all the following:
(a) Confirm the identity and determine the exclusion status of providers and any person with an ownership or control interest or who is an agent or managing employee of the provider through routine checks of Federal databases.
(b) Check the Social Security Administration’s Death Master File, the National Plan and Provider Enumeration System (NPPES), the List of Excluded Individuals/Entities (LEIE), the System for Award Management (SAM) (formally the Excluded Parties List System (EPLS)), and any such other databases as the Secretary may prescribe.
(c)(1) Consult appropriate databases to confirm identity upon enrollment and re-enrollment; and
(c)(2) Check the LEIE and SAM (formerly the EPLS) no less frequently than monthly.
Both OIG Exclusions and SAM Debarments are required because they serve distinct, though overlapping, purposes in protecting federal funds and programs.
OIG (Office of Inspector General) exclusions target individuals/entities prohibited from participating in Medicare and Medicaid. Whereas, SAM (System for Award Management) debarments cover broader exclusions from all federal contracts, grants, and loans.
- Different Scope & Authority: OIG focuses on healthcare fraud/patient harm. SAM covers a wider range of actions, including non-healthcare fraud, tax delinquency, and national security violations.
- No One-to-One Overlap: An individual might be excluded from Medicare by the OIG but not yet listed in SAM, or vice versa (e.g., a contractor debarred from federal construction projects for fraud who then applies to a clinic).
- Legal Compliance and Penalties: Federal law prohibits paying any excluded provider using federal funds (Medicare/Medicaid). Hiring or contracting with an entity listed on either database can result in severe civil monetary penalties (CMPs) and loss of funding.
- Completeness: While the OIG’s List of Excluded Individuals and Entities (LEIE) is specific, SAM often includes actions from multiple federal agencies, serving as a more comprehensive, overall federal screening tool.
In short, auditing both databases is necessary to ensure complete compliance and avoid liability, as they are not always synchronized, and a “clean” record on one does not guarantee exclusion from the other.
OIG Exclusion Authority
The OIG is a federal agency with authority under Sections 1128 and 1156 of the Social Security Act (Act) to exclude individuals or entities from federally funded healthcare programs, including Medicaid, the Children’s Health Insurance Program (CHIP), and Medicare, and to seek Civil Monetary Penalties (CMPs) for various types of prohibited conduct.
Section 1128 of the Act covers Medicare, Medicaid, and all other federal healthcare programs that provide benefits funded directly or indirectly by the United States.
Section 1156 extends this scope to include the state-level counterparts of Medicare and the health programs under Section 1128.
The Office of Inspector General (OIG) maintains the List of Excluded Individuals/Entities (LEIE) that is updated monthly.
Mandatory Exclusions
The OIG is required by law to exclude from participation in all Federal health care programs individuals and entities convicted of the following types of criminal offenses:
- Medicare or Medicaid fraud and other crimes related to the delivery of items or services under Medicare, Medicaid, SCHIP, or other State Health Care programs.
- Patient abuse or neglect.
- Felony convictions for other healthcare-related fraud, theft, or financial misconduct.
- Felony convictions relating to the unlawful manufacture, distribution, prescription, or dispensing of controlled substances.
Permissive Exclusions
The OIG has the discretion to exclude individuals and entities on several grounds, including (but not limited to):
- Misdemeanor convictions related to health care fraud other than Medicare or a State Health Care program, fraud in a program (other than a health care program) funded by any Federal, State, or local government agency.
- Misdemeanor convictions relating to the unlawful manufacture, distribution, prescription, or dispensing of controlled substances; suspension, revocation, or surrender of a license to provide healthcare for reasons related to professional competence, professional performance, or financial integrity.
- Provision of unnecessary or substandard services.
- Submission of false or fraudulent claims to a Federal health care program.
- Engaging in unlawful kickback arrangements.
- Defaulting on health education loan or scholarship obligations.
- Controlling a sanctioned entity as an owner, officer, or managing employee.
SAM Federal Contracts Procurement Repository
The General Services Administration (GSA) System for Award Management (SAM) lists individuals and entities suspended or debarred from obtaining new federal contracts, certain subcontracts (procurement), discretionary assistance, certain funded lower-tiered transactions, leases, loans, loan guarantees, and other benefits (non-procurement).
Unlike the Office of Inspector General (OIG), the GSA serves as a procurement repository and lacks the authority to impose Civil Monetary Penalties (CMPs) on individuals or entities.
Healthcare organizations must screen new hires, existing employees, and vendors to avoid doing business with sanctioned, debarred, or excluded parties.
If an individual or entity is debarred, it might not mean you cannot do business with them. Always contact the issuing Agency if you have questions about an exclusion record.
If your organization does not require your vendor to be GSA-approved, nor is it reimbursed through federal program dollars, the debarment may not affect your contract.
Differences between OIG-LEIE and GSA-SAM
The two lists do overlap regarding excluded healthcare providers. It is entirely possible to find the provider on both lists.
The Office of Inspector General has the authority to exclude individuals or entities from federally funded healthcare programs and to seek Civil Monetary Penalties (CMP) for various types of prohibited conduct.
In contrast, the General Services Administration lacks the authority to impose financial penalties, as it serves as a procurement repository and lacks jurisdiction over such matters.
Search HealthProviders DB
HealthProviders DB profiles include all Federal & State Exclusions, Terminations, Suspensions, Sanctions, and Debarments Lists, mapped as Exact or Possible matches, greatly simplifying your exclusion screening.
Exclusions that match by NPI number, or by full name and address, are “Exact” matches.
Exclusions are imported monthly as they become available, ensuring the Healthcare Provider Profiles are always up to date.
An individual or organization whose billing privileges have been revoked by the OIG or any State cannot participate in Medicaid, Medicare, or the Children’s Health Insurance Program (CHIP).
Learn more about who needs to be screened.
Enter an NPI number, license number, or provider name in the search field below to search the Exclusions.
Alternatively, you can also search the Providers.
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Select a State to view the list of Exclusions by State.
Additionally, you can narrow the list by city, among other options, from the Filter Panel, which you can open by clicking the vertical ellipses ⋮ in the upper right corner of the app.
Use HealthProviders DB Batch Exclusion Screening and Exclusion-monitoring Solutions to avoid potential Civil Monetary Penalties.