Monthly Exclusion Screening: OIG LEIE, SAM.gov and State Medicaid Lists

Exclusion screening is one check in a sequence that also includes license verification and background checks: our behavioral health hiring hub collects the whole process, and the full hiring screen explains how the three checks differ and in what order to run them.

This page stays on the exclusion check itself, because it reaches further into a behavioral health roster than the clinician list suggests.

The payment ban is the starting point.

Federal health care programs will not pay for any item or service an excluded individual or entity furnishes, orders or prescribes, on or after the exclusion's effective date (42 CFR 1001.1901(b)).

OIG says the ban applies to anyone who employs or contracts with the excluded person, regardless of who submits the claims, and its 2013 bulletin applies it to employees, contractors and volunteers alike.

It also reaches people who never touch a client.

The ban covers administrative and management services even when they are not separately billable, and OIG's bulletin names leadership roles — CEO, CFO, HR director, practice office manager — plus billing, accounting, IT, staff training and HR services, unless those services are wholly unrelated to federal health care programs.

In a practice that bills Medicaid or Medicare, that reads across behavioral health technicians, RBTs, peer specialists, intake coordinators and billing staff, not only the licensed clinicians.

CMS's 2009 State Medicaid Director Letter makes the same point in our field: it lists services performed by excluded social workers employed by health care entities to serve Medicaid recipients among the services Medicaid cannot pay for.

OIG's own mechanism for deciding how far to go is to review each job category and each contract, and where the work is directly or indirectly payable by a federal health care program, screen everyone in that category.

Staff supplied by a staffing agency are part of that: OIG recommends screening them yourself, or relying on the agency's screening only after validating that the agency actually does it.

The one setting where the question changes is a practice with no federal money at all.

If federal health care programs do not pay, directly or indirectly, for the items or services a person provides, a provider may employ or contract with that excluded person for those items or services.

Any Medicaid, Medicare or other federal billing for anything the person furnishes brings the full ban back.

OIG warns that anyone who hires an individual or entity on the LEIE may face civil monetary penalties, and advises health care entities to check the list for both new hires and current employees.

People get on it for reasons that land squarely in behavioral health hiring: OIG must exclude people convicted of patient abuse or neglect offenses connected to health care, health care fraud, and felony controlled-substance offenses committed by health care-related individuals.

The mechanics are simple.

The LEIE's online search checks up to five names at a time and can confirm a match with a Social Security number for an individual or an EIN for an entity; the downloadable LEIE file carries no SSNs or EINs, so use the online search to confirm or clear any name match.

Search every name the person has used — OIG's bulletin gives maiden names as the example — because an entry under a former name will not surface under the current one.

Document each search as you run it.

OIG recommends keeping documentation of the initial name search, such as a printed screenshot showing the results, along with any additional searches.

The screenshot is what turns a monthly habit into a record.

Two traps when reading results.

First, both versions of the LEIE are generally updated by the middle of each month with all actions taken during the prior month, so an exclusion action from this month may not be visible yet — which is the practical reason the search repeats monthly.

Second, reinstatement is not automatic once the specified exclusion period ends: the person must apply and receive written notice of reinstatement, so a date that has passed on paper does not clear someone still shown on the list.

One limit to keep straight: a clean LEIE result is not a clean license.

OIG says a license revocation, suspension or surrender can lead to exclusion, but probation, letters of censure and reprimands do not qualify as a basis for exclusion — so a clinician can be under active board discipline with no LEIE entry at all.

License verification at the state board stays its own check.

SAM.gov is administered by GSA and collects debarment actions taken by many federal agencies, including OIG's exclusions, while the LEIE lists only OIG exclusion actions.

OIG still recommends the LEIE as the primary source for exclusion screening — and it is direct about the enforcement difference: it has no authority to impose civil monetary penalties for employing a person who is debarred — listed only in SAM.gov, for example — but not excluded by OIG.

The SAM.gov duty often reaches a behavioral health practice through a contract rather than through the exclusion rules themselves.

Medicaid managed care plans may not knowingly have a relationship, including a network provider relationship, with anyone debarred or suspended under federal procurement rules or excluded under section 1128 or 1128A (42 CFR 438.610), so in-network employers often meet SAM.gov screening duties through their MCO contracts.

Running the SAM.gov search alongside the LEIE each month keeps you ahead of the contract question.

The monthly duty you can point to in regulation is the state's, not yours.

State Medicaid agencies must check the LEIE and EPLS — the exclusion list now housed in SAM.gov — no less often than monthly, and in connection with new enrollments, so they do not enroll or continue the enrollment of an excluded individual or entity (42 CFR 455.436).

That rule binds the state agency.

CMS recommends, but does not mandate, that states require providers to screen their own employees monthly.

CMS's 2009 letter to State Medicaid Directors pushed further: it told states they should require Medicaid providers to search the OIG exclusion list monthly as a condition of enrollment and to report any exclusion found, and said states that keep their own exclusion lists should remind providers to search them whenever they search the LEIE.

Whether your state adopted that guidance is a state-by-state question, and your Medicaid provider agreement is where it would show up — read it.

The number of states that keep their own Medicaid exclusion list has no verified answer: no primary source counts them, and vendor pages disagree with each other.

These are the state lists verified in the research for this guide.

If your state is not in the table, that is not evidence it has no list — ask your state Medicaid agency.

The Texas row carries the sharpest operational point: Texas HHS's Office of Inspector General says the employer that discovers a current employee is excluded has a responsibility to notify it.

A match is not only a hiring problem — see the last section.

Be precise about what kind of rule monthly screening is.

OIG's 2013 Updated Special Advisory Bulletin on the Effect of Exclusion (May 8, 2013) says there is no statutory or regulatory requirement to check the LEIE, so providers may decide how frequently to check.

Monthly is OIG's recommendation, for a mechanical reason: OIG updates the LEIE monthly, so screening employees and contractors each month best minimizes potential overpayment and CMP liability.

The exposure it manages is worth reading in the regulation.

Under 42 CFR 1003.200(b)(4), OIG may impose a penalty, assessment and exclusion on anyone who employs or contracts with a person they know — or should know — is excluded, for items or services payable by a federal health care program.

The penalty provision at 42 CFR 1003.210(a)(4) sets a statutory maximum of $20,000 per item or service for conduct after February 9, 2018; the older $10,000 figure still quoted in places applies only to conduct on or before that date.

On top of the penalty, OIG may impose an assessment of up to 3 times the amount claimed for each item or service — or, for services that are not separately billable, up to 3 times the excluded person's total costs, including salary, benefits and taxes (42 CFR 1003.210(b)(2)).

The maximum penalty is inflation-adjusted: 45 CFR 102.3 lists $25,595 as the 2025 maximum for employing or contracting with an excluded individual, and no 2026 adjustment had appeared when we checked eCFR in October 2026.

The phrase to notice is per item or service — exposure scales with each item or service an excluded person furnishes.

A vendor or HR platform can run these searches on a schedule, and handing off the work is fine — but it does not hand off the liability.

OIG says a provider that outsources LEIE screening to another company keeps the potential CMP liability if it employs or contracts with an excluded person, so keep the search documentation in your own files and confirm the vendor's list actually matches your roster, including new hires and agency staff.

One database does not belong in this routine: OIG recommends the LEIE, not the NPDB, as the primary database for exclusion screening of current and potential employees and contractors.

A monthly hit on a current employee is the scenario the routine exists for, and the first moves are operational.

Confirm the match with the SSN or EIN check rather than acting on the name alone, then take the person out of any role that touches federally payable items or services — clinical work, and also the billing, HR, IT and management duties the payment ban covers.

Check the current record before assuming an old exclusion expired: reinstatement requires an application and written notice.

If the person has already been working in federally payable roles, OIG's own guidance points to its Self-Disclosure Protocol — its exclusions FAQ says, "If you have already employed the individual, check the Self-Disclosure Protocol."

OIG's bulletin frames the underlying stakes as potential overpayment as well as CMP liability.

The protocol's own mechanics were outside this page's research — read the protocol itself and involve an attorney who handles CMP matters before you file anything.

Texas adds a notification duty of its own.

Texas HHS's Office of Inspector General says an employer that discovers a current employee is excluded has a responsibility to notify the OIG, so a Texas practice's calls are to counsel and to the state OIG.

Whether other states have a similar requirement is a per-state question — ask your state Medicaid agency or its OIG.