OIG, GSA, and SAM Sanctions Screening: A Guide for Healthcare Employers

TL;DR

• Healthcare employers should check three layers. The OIG LEIE covers federal healthcare exclusions, SAM covers broader federal suspensions and debarments, and state Medicaid lists contain separate state actions.
• Screen employees, contractors, owners, volunteers, and vendors whose work furnishes or supports items or services payable by a federal healthcare program.
• Screen before hiring or contracting, then repeat the checks monthly as a compliance practice. OIG updates the LEIE monthly, so a pre-hire search cannot identify exclusions added later.
• Employing an excluded person can expose an employer to civil monetary penalties, repayment demands, and potential False Claims Act liability.
• The vendor evaluation and FAQ below explain how to choose screening support and handle common compliance questions.

The three lists healthcare employers must check

Healthcare employers need three layers of sanctions screening because each source records actions under a different authority. An OIG exclusion check cannot replace a SAM exclusion check, and neither federal search captures every state Medicaid action.

The HHS Office of Inspector General maintains the List of Excluded Individuals and Entities, commonly called the LEIE. OIG can exclude a person or business from federally funded healthcare programs. An excluded party cannot receive federal healthcare program payment for items or services they furnish, order, or prescribe. Employers can conduct an OIG exclusion list search through the online lookup tool or a downloadable file.

The General Services Administration operates the System for Award Management, known as SAM. Its exclusions records cover suspensions, debarments, and other restrictions imposed across the federal government. A SAM exclusion check can therefore identify federal contracting restrictions that do not appear in the healthcare-specific LEIE. Some records overlap with OIG actions, but SAM serves a broader purpose than preventing healthcare program payments.

State Medicaid agencies maintain the third layer under their own enforcement authority. Their lists may record providers, contractors, or entities excluded from a state Medicaid program that may not appear in the federal LEIE. A ProviderTrust analysis of OIG, SAM, and state Medicaid lists reports that about half of the state Medicaid exclusions it reviewed did not appear on the LEIE. A state exclusion may also prompt action by another state or affect participation under that state's rules, but the consequences vary by jurisdiction.

A complete screening policy treats the LEIE, SAM, and state Medicaid lists as separate sources. The LEIE addresses federal healthcare payment eligibility, SAM records broader federal restrictions, and state lists close reporting gaps left by the federal databases.

Who counts as screening-eligible staff

Screen anyone whose work contributes to care or costs billed to a federal healthcare program. Physicians and nurses belong on the roster, but so do billing staff, coders, and administrators whose work supports Medicare or Medicaid claims. The OIG payment prohibition can cover administrative and indirect services connected to federally reimbursed items or services.

Use two questions to decide whether a person or entity belongs on the screening roster. Could their work appear in a claim, cost report, prescription, order, or supporting record submitted to Medicare or Medicaid? Could federal program funds pay for their work directly or through your organization? A yes to either question supports screening.

Your roster may therefore include employees, contractors, temporary workers, owners, volunteers, and vendors. Screening can apply even when a worker has no patient contact. For example, an excluded biller can create exposure by preparing claims, while an excluded contractor can create exposure when your organization includes that contractor's services in reimbursable costs. When a role remains uncertain, review its funding source and claim connection rather than relying on its job title.

How often to screen, and how to document it

A defensible screening schedule checks each person before hire and reviews the active roster every month afterward. OIG updates the LEIE monthly and advises healthcare providers to check it routinely, while federal guidance separately directs state Medicaid agencies to check exclusion status during enrollment and reenrollment and on a monthly basis. Applying the same monthly schedule to SAM and relevant state Medicaid lists gives employers a consistent process for finding actions added after the initial search.

Include employees, contractors, vendors, and entities in the recurring roster for as long as their work could affect federally funded healthcare services. Assign one person or screening platform to manage the roster, run each search, investigate possible matches, and preserve the records.

Audit-ready documentation should show exactly how you completed each check. Record the search date and every database queried. Preserve the legal name, aliases, date of birth, and professional identifiers used in the search. When permitted and appropriate, use an SSN, EIN, NPI, or license information to confirm identity, and protect those identifiers under your privacy and data-security procedures.

For each possible match, document the comparison and the evidence supporting your decision. Record whether the match was confirmed or cleared, who reviewed it, and when the review occurred. Keep the original search output or vendor report with the resolution notes. A monthly log should also identify roster additions and removals so an auditor can verify that no active worker missed a screening cycle.

What noncompliance costs

Civil monetary penalties can apply to each affected item or service when an employer knew or should have known that an excluded person furnished it. The maximum amounts vary by violation and receive annual inflation adjustments, so employers should consult the current OIG civil monetary penalty authorities rather than rely on the former $10,000 statutory amount. OIG may also seek an assessment of up to three times the amount claimed.

False Claims Act exposure follows a separate legal track. An employer may face False Claims Act liability if it knowingly submits false Medicare or Medicaid claims connected to an excluded person or knowingly and improperly retains an identified overpayment. Repeated claims can multiply the exposure, and employers may also incur repayment obligations and legal costs.

Nonclinical employees can create the same payment problem. The OIG payment prohibition covers services furnished directly or indirectly, including administrative and billing work included in claims or reported costs. Claims or reported costs that include an excluded biller's services may therefore require review even though the biller did not treat patients.

Other consequences can continue after the immediate dispute. Depending on the facts and applicable state law, a patient injury involving an excluded worker could lead to negligent hiring or retention allegations. As part of resolving a federal healthcare fraud matter, OIG may also negotiate a Corporate Integrity Agreement that requires audits, reporting, and compliance oversight for a defined period. Employers should involve counsel promptly when screening identifies a possible match because the correct response depends on the person's role, exclusion status, and connection to federal claims.

How to evaluate a sanctions screening vendor

Evaluate sanctions screening vendors by their database coverage, monitoring schedule, audit records, and workflow compatibility.

• Full coverage should include the OIG LEIE, SAM exclusions, and every relevant state Medicaid exclusion list.
• Automated monitoring should re-screen employees and contractors each month without requiring manual uploads.
• Audit-ready records should document each search and preserve how potential matches were resolved.
• Workflow integration should connect screening results with your existing background check, credentialing, or HR tools.

Confirm each capability in the proposed package. A vendor's general background screening services do not guarantee complete sanctions coverage.

5 Star Background Checks for small and mid-sized healthcare employers

5 Star Background Checks uses per-test pricing without minimum-order requirements or a required enterprise contract. The company serves clinics, small practices, and staffing agencies that want ordering volume to follow their hiring needs.

A suitable sanctions screening package still needs to meet all four evaluation criteria. Ask 5 Star to confirm that the selected service covers the OIG LEIE, SAM, and every relevant state Medicaid list. You should also verify monthly automated re-screening, documented match resolution, and compatibility with your hiring or credentialing workflow.

Flexible ordering can help smaller employers tie screening purchases to hiring volume. Large hospital systems may instead require extensive integrations or multi-state implementation support. Choose 5 Star Background Checks based on confirmed list coverage, screening volume, documentation requirements, and workflow compatibility rather than employer size alone.

When a large hospital system needs an enterprise vendor instead

Large hospital systems may consider enterprise vendors when they operate in several states or require extensive applicant tracking system and human resources information system connections. Checkr, GoodHire, HireRight, and Sterling, now part of First Advantage, are possible substitutes when integration scale or international screening matters more than flexible ordering. Sterling reports screening coverage in more than 240 countries and territories, but geographic reach does not establish complete healthcare sanctions coverage.

Scale alone does not confirm healthcare sanctions coverage. Public product information reviewed for this article does not confirm that Checkr, GoodHire, HireRight, or Sterling covers the OIG LEIE, SAM, and every relevant state Medicaid list with monthly monitoring. Before signing, require written confirmation of each database, update frequency, match-resolution procedure, audit records, and integration scope. A specialized enterprise compliance vendor may suit a multi-state hospital better when state-specific coverage and implementation support carry more weight than flexible per-test ordering.

Next step: build a defensible screening process

A defensible program screens covered employees and contractors before work begins and every month afterward. Keep records of the identifiers searched, lists checked, results, and match resolutions. Consistent screening and documentation give auditors evidence of what you checked, when you checked it, and how you resolved possible matches.

Smaller clinics, practices, and staffing agencies can contact 5 Star Background Checks to discuss list coverage, monitoring frequency, and reporting options. Its per-test pricing and no-minimum-order model may suit employers that want to avoid an enterprise contract.

FAQ

How often should healthcare employers run exclusion screening?

Exclusion screening checks whether a worker or entity appears in a relevant federal or state exclusion database, and employers commonly perform it before hire and monthly afterward. Employers considering 5 Star Background Checks should confirm that the selected service checks the OIG LEIE, SAM, and applicable state lists on that schedule. Monthly screening can identify exclusions added after onboarding because OIG updates the LEIE each month.

What should I do if an employee or contractor appears on an exclusion list?

A search result is a possible match until identifying information confirms that the record belongs to the employee or contractor. If a 5 Star Background Checks report returns a possible match, follow your escalation procedure, restrict affected federally reimbursable work when appropriate, and verify the person's identifiers before taking employment action. Compliance counsel can assess reporting duties, payment exposure, and appropriate personnel action based on the confirmed status and the person's role.

Is a one-time pre-hire exclusion check enough?

A one-time pre-hire check shows only whether the searched databases contained a matching exclusion record on that date. Employers using 5 Star Background Checks should pair initial screening with monthly monitoring of the applicable lists. Ongoing monitoring helps employers identify later exclusions before additional affected claims or costs accumulate.