Excluded-list screening is a core control in provider enrollment and an important part of a practice’s credentialing workflow. A missed exclusion can put payer participation and claims at risk; a name-only match can disrupt onboarding unnecessarily. The solution is a consistent process that checks the right databases, confirms identity, and records what your team did.
The three databases to know
1. OIG LEIE
The U.S. Department of Health and Human Services Office of Inspector General maintains the List of Excluded Individuals/Entities (LEIE). Exclusion bars participation in federal healthcare programs, including Medicare, Medicaid, and CHIP. Federal programs generally do not pay for items or services furnished, ordered, or prescribed by an excluded person, and hiring or billing with an excluded individual can create civil monetary penalty (CMP) and overpayment risk.
OIG updates the LEIE monthly. Its LEIE search and download resources support both individual lookups and broader screening workflows.
2. SAM.gov
SAM.gov’s exclusions records cover federal procurement and nonprocurement debarments. They are separate from the LEIE, so a clean result in one database does not replace checking the other. Payers, hospitals, and other organizations may also include SAM.gov screening in their onboarding or ongoing review processes.
Search the SAM.gov exclusions database, and investigate possible matches before taking action.
3. State Medicaid exclusion and termination lists
States maintain their own Medicaid exclusion, termination, or sanctions information, and the lists and procedures vary. A state action can affect enrollment in that program and can complicate a practice’s multi-state enrollment oversight. Check the relevant state agency’s current resources rather than assuming a federal search captures every state-level action.
Who checks, and how often?
The State Medicaid agency has a defined federal duty: under 42 CFR § 455.436, it checks specified federal databases for provider identity and exclusion status at enrollment and reenrollment, and checks LEIE and the former EPLS database, now accessed through SAM, at least monthly.
In practice, payers may screen during enrollment and recredentialing; CVOs and hospital medical staff offices may also conduct checks. Responsible organizations commonly build recurring screening into their compliance processes. Monthly screening is a common operational norm, but obligations vary by program, state rules, contracts, and organizational policy. OIG recommends screening before hiring or contracting and periodically thereafter; consult counsel to determine what applies to your organization.
A practical screening protocol
- Screen before enrollment. Check new hires and providers before submitting payer applications or billing.
- Repeat checks on a schedule. Include active providers and relevant workforce members in a documented recurring process.
- Use identifiers, not names alone. Search using available identifiers such as name, date of birth, and NPI. Re-verify after a name change.
- Keep an audit trail. Record the database, search date, identifiers used, reviewer, result, and resolution.
- Use a response plan for possible hits. Confirm identity, pause affected enrollment or billing decisions as appropriate, obtain legal review, and notify payers or agencies when required.
False positives happen. A name match does not establish that the listed person is your provider. Verify identifiers and the underlying record before making a decision.
Veracity Take
Exclusion screening is the early-warning system behind clean enrollment. A missed match can expose your practice to repayment and penalty risk; an unverified match can stall an otherwise valid application. Make screening repeatable, documented, and responsive to changes.
For a broader view of onboarding controls, see The Complete Provider Onboarding Checklist.
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