You know it’s essential to screen new hires, current employees, and vendors against the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE), the General Services Administration (GSA) System for Award Management (SAM), and all available State Exclusion lists.
But why all these databases, and what’s the difference?
The LEIE is the list of individuals or entities that the Office of Inspector General (OIG) excludes from federally funded healthcare programs, including Medicaid, Children’s Health Insurance Program (CHIP), and Medicare programs.
The General Services Administration (GSA) System for Award Management (SAM) is a list of individuals and entities suspended and 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).
State exclusion lists include individuals and entities that are excluded from participating in Medicaid, CHIP, and Medicare programs for violating State laws.
The OIG List of Excluded Individuals and Entities (LEIE)
The Office of Inspector General (OIG) maintains the List of Excluded Individuals/Entities (LEIE) that is updated monthly.
HealthProviders DB imports the LEIE each month, so the database is always up to date. The LEIE data is normalized, aggregated, and matched with the Healthcare Providers’ Profile as Exact or Possible matches, greatly simplifying your research.
OIG Authority
The OIG has the authority under Section 1128 and Section 1156 of the Social Security Act (Act) to exclude individuals and entities from federally funded healthcare programs for various reasons, including but not limited to convictions for Medicare or Medicaid fraud.
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.
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 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 health care for reasons bearing on 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.
The System for Award Management (SAM)
The General Services Administration (GSA) maintains the System for Award Management (SAM) of individuals and entities that are suspended and debarred from participating in federal contracts, grants, loans, subcontracts, and other assistance programs.
Healthcare organizations should not hire individuals or entities on the SAM.gov list to avoid conducting business with a sanctioned, debarred, or excluded party.
HealthProviders DB imports the HHS and OIG Suspensions and Debarments daily, so the database is always up to date. The SAM Suspensions and Debarments are normalized, aggregated, and matched with the Healthcare Providers’ Profile as Exact or Possible matches, greatly simplifying your research.
Differences between OIG-LEIE and GSA-SAM
The two lists do often 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 does not have the authority to impose any financial penalties because it serves as a procurement repository and is not an agency with jurisdiction over such matters.
- The LEIE is a list of excluded individuals and entities from federally funded healthcare programs.
- SAM is a procurement repository of suspended and debarred individuals and entities from obtaining new Federal contracts, certain subcontracts (procurement), discretionary assistance, certain funded lower-tiered transactions, leases, loans, loan guarantees, and other benefits (non-procurement).
State Medicaid Exclusion Lists
Every state has a department or agency dedicated to upholding the integrity of its Medicaid programs and public health initiatives. While the names of these enforcement authorities may differ—such as the Department of Medicaid or the Department of Health Care Services—they all establish rules regarding the ineligibility of providers who have been disciplined or have lost specific licensing privileges.
Only forty-three States currently publish an exclusion list. New Mexico, Oklahoma, Rhode Island, South Dakota, Utah, Virginia, and Wisconsin do not keep a State exclusion list. Instead, you are referred to the Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE).
Unfortunately, each State publishes its Medicaid exclusion lists in different formats and with varying levels of detail. Some States provide only the name of the excluded individual or entity, along with a possible address and sometimes just a city.
HealthProviders DB imports all of the State Exclusion Lists when they become available each month, so the database is always up to date.
State exclusion lists data is normalized, aggregated, and matched with the Healthcare Providers’ Profile as Exact or Possible matches, greatly simplifying your research.
HealthProviders DB is an unparalleled solution to effortlessly and simultaneously search OIG Exclusions, SAM Exclusions, State Exclusion Lists, FDA Debarment, and Clinical Investigators—Disqualification Proceedings—all in one powerful platform!