OIG LEIE Monthly Exclusion Screening: Process + Audit-Ready Logs

The OIG LEIE database must be screened monthly for every workforce member, credentialed provider, and contractor whose services are billed to a federal healthcare program. Missing an exclusion exposes the practice to civil monetary penalties of up to $25,595 per item under 42 CFR § 1003.210(a)(4) (2026 inflation-adjusted amount; statutory authority at 42 USC § 1320a-7a) plus treble damages. Screen the LEIE, SAM.gov, and applicable state Medicaid exclusion lists on the same monthly cadence.

Cadence: why monthly, not quarterly

The OIG's Special Advisory Bulletin on the Effect of Exclusion recommends monthly screening. CMS State Medicaid Director Letter #09-001 requires that state Medicaid programs ensure providers do not employ or contract with excluded individuals — and most state Medicaid contracts pass that obligation through as monthly screening.

Quarterly does not catch a hire who became excluded mid-month, nor a vendor whose principal was excluded shortly after onboarding. Annual is essentially indefensible if the practice bills Medicare or Medicaid. The LEIE is updated by OIG within 30 days of each exclusion action; SAM.gov updates daily. Monthly screening keeps the practice's evidence window inside the OIG's update cycle.

In our analysis of 400+ d3rx client binders, the most common failure mode is not running the screen at all for back-office contractors. The second most common is running the screen monthly for W-2 staff but only at credentialing for providers, missing a provider who is excluded during the term of employment.

Who must be screened

Cast a wide net. The OIG, CMS, and most state Medicaid agencies treat "person who furnishes items or services" expansively.

| Population | Source list | Screening cadence | |---|---|---| | W-2 employees with PHI or billing access | HR roster | Monthly | | Credentialed providers (MD, DO, NP, PA, DC, etc.) | Credentialing file | Monthly | | Locum tenens and 1099 clinicians | Contractor list | Monthly | | Volunteers in clinical roles | Volunteer roster | Monthly | | Vendors who directly furnish billable items (DME, lab) | Vendor list | Monthly (entity + principals) | | Back-office vendors (RCM, transcription, IT MSP, EHR) | BAA vendor list | Quarterly minimum + executed attestation | | Owners and board members | Ownership/governance file | Monthly |

Add every new hire and every new contracted entity to the screening list before their start date. The first screen happens before the first paycheck or invoice, not after.

The monthly workflow

``` Step 1 — Build / refresh the screening roster (first business day of the month) Pull HR roster, credentialing file, contractor list, vendor list, ownership file. Cross-check against last month's roster — flag any additions, terminations, or name changes.

Step 2 — Run LEIE screen (https://oig.hhs.gov/exclusions/) Search by name and (for entities) by EIN or NPI. Export the "no records found" or "match found" result per name.

Step 3 — Run SAM.gov screen (https://sam.gov/search/exclusions) Search by name and (for entities) by Unique Entity ID. Export the result per name.

Step 4 — Run state Medicaid exclusion screen Apply each state where the practice bills Medicaid. Use the state's published exclusion list URL; some states delegate to LEIE + attestation, others publish their own list.

Step 5 — File the dated evidence in the compliance binder One per month, named YYYY-MM exclusion screening log.

Step 6 — Escalate any hit immediately (see escalation path below). ```

For a practice with under 50 names on the roster, the LEIE + SAM.gov + one state Medicaid list takes a trained staff member roughly 45 minutes per month via the free databases. Paid aggregators reduce that to under 10 minutes per month and provide an audit-formatted PDF log.

The audit-ready monthly log

This is the exact table format that survives an OCR or OIG audit. Embed it in the compliance binder, one row per screened person/entity per month.

| Date screened | Name (last, first) or entity | Role | NPI / EIN | LEIE result | SAM.gov result | State Medicaid result | Screener (initials) | |---|---|---|---|---|---|---|---| | 2026-05-01 | Adams, Jane (MD) | Credentialed provider | 1234567890 | No record | No record | CA — No record | JS | | 2026-05-01 | Brown, Marcus | Medical assistant | n/a | No record | No record | CA — No record | JS | | 2026-05-01 | RCM Vendor LLC | Billing contractor | EIN 12-3456789 | No record | No record | n/a | JS | | 2026-05-01 | Chen, Lisa (NP) | Locum tenens | 9876543210 | Match | No record | CA — pending verify | JS |

A "Match" entry triggers the escalation workflow immediately. The log is not the place to resolve a match — it is the place to record that the match was identified on a specific date.

Required columns auditors look for

• Date of screen (not just month — exact date).
• Full legal name, including any prior names or aliases noted in HR file.
• Role (credentialed provider, employee, contractor, vendor).
• NPI for individuals, EIN for entities.
• Result per database (LEIE, SAM.gov, every state Medicaid list in scope).
• Screener's name or initials.
• Retention: at least 10 years for federal-program billing entities.

Evidence to retain

For every monthly screening cycle, file in the binder:

1. The roster used (CSV or PDF) — proof of who was screened.
2. The full result page or export per name (a "no record found" screenshot per name OR an aggregated paid-service PDF).
3. The dated log table above.
4. For any match: the verification artifacts (date-of-birth match, SSN last-4, employment dates).
5. Vendor attestations for any back-office vendor whose own staff are not directly screened by the practice.

Retention guidance: 10 years aligns with the False Claims Act statute of limitations and the Medicare Program Integrity Manual recordkeeping expectation. Some state Medicaid contracts require longer.

Escalation path on a match

A LEIE or SAM.gov match is a stop-the-bus event. The workflow:

1. Within 1 business day: verify the match is the same person — date of birth, prior names, NPI cross-check on NPPES. False positives on common names are routine; do not act on a name-only match without verification.
2. If verified: stop billing for any services furnished by the individual immediately. Document the stop with a dated note.
3. Within 5 business days: notify external healthcare counsel. Excluded-person hiring is a 60-day Overpayment Rule and often a False Claims Act event.
4. Within 60 days of identification: assess and refund any overpayments for services furnished by the excluded individual. The 60-day clock starts when the overpayment is identified, not when the screen is run.
5. Consider OIG Self-Disclosure (SDP) for any extended employment. SDP settlements are typically multiple-times lower than litigated CMPs.
6. File the matter in the binder: dated match, verification, stop-billing date, refund record, counsel engagement, SDP outcome.

This is exactly where a binder pays for itself — the dated evidence trail produced by routine monthly screening is the difference between a self-disclosed administrative matter and a CMP referral.

State preemption and Medicaid carveouts

State Medicaid agencies publish their own exclusion lists and impose state-specific screening requirements that go beyond the federal LEIE. California, New York, Texas, Florida, Pennsylvania, and Ohio each maintain a state Medicaid exclusion list with monthly screening expectations. Some states (e.g., Texas via the Texas Health and Human Services OIG list) require screening against the state list as a contractual term of Medicaid participation.

If you bill multiple state Medicaid programs, the screening roster includes the federal LEIE + SAM.gov + each state's list — not just the practice's home state.

What goes wrong

The five recurring defects in d3rx's binder review:

1. Screen is run monthly for W-2 staff but only at credentialing for providers, missing mid-employment exclusion.
2. Back-office vendors are never screened and no attestation is on file.
3. Log entries record "no record found" but no roster is filed — auditor cannot verify who was actually screened.
4. NPI/EIN columns are blank, so common-name false positives are not resolved.
5. A match is recorded but no escalation evidence (counsel, stop-billing, refund) follows in the binder.

How d3rx fits

The d3rx compliance binder tracks the monthly screening roster, files the dated evidence per cycle, and prompts on every new hire or new vendor to add them to next month's screen. It is an administrative documentation aid, not a substitute for counsel on a confirmed match. The practice remains responsible for running the screens and for the billing decisions on a match.