Table of Contents
In the heavily regulated healthcare industry, compliance isn’t just a best practice — it’s a legal obligation. One of the most critical compliance tasks for healthcare providers, suppliers, and related organizations is conducting monthly OIG exclusion checks. Failing to properly verify whether employees, contractors, or vendors are on the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities (LEIE) can result in hefty penalties, reputational damage, and even legal consequences.
In this article, we’ll explore why monthly OIG exclusion checks are essential, how they work, and best practices to help your organization stay compliant.
What Are OIG Exclusion Checks?
The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) maintains the LEIE — a public list of individuals and entities that are excluded from participation in federally funded healthcare programs such as Medicare and Medicaid.
An exclusion typically stems from criminal convictions, fraud, patient abuse, licensing board actions, or defaulting on health education loans. Employers who unknowingly or negligently hire or contract with excluded individuals or organizations risk facing civil monetary penalties (CMPs) and denial of federal funds.
Why Monthly Checks Matter
While the LEIE is updated regularly, many healthcare providers make the mistake of only conducting exclusion checks during hiring or on an annual basis. This approach leaves a significant compliance gap. Here’s why monthly OIG exclusion checks are critical:
1. Real-Time Risk Management
Employees and contractors can be added to the LEIE at any time. A monthly check ensures that you catch new exclusions promptly and take appropriate action before services are billed to federal healthcare programs.
2. Avoid Costly Penalties
The OIG can impose CMPs of up to $10,000 per item or service provided by an excluded individual or entity. By running monthly checks, you show due diligence and reduce the risk of financial penalties.
3. Protect Organizational Reputation
Healthcare organizations must maintain trust with patients, regulators, and payers. Discovering that your organization employs or contracts with an excluded individual can lead to public relations issues and audits.
4. Meet Federal and State Compliance Requirements
Although not explicitly required by law to check monthly, the OIG and Centers for Medicare & Medicaid Services (CMS) recommend routine, periodic screenings. Many organizations and compliance officers interpret this guidance as a monthly obligation to ensure consistent compliance.
How to Perform Monthly OIG Exclusion Checks
Conducting these checks manually can be time-consuming, especially for large organizations with hundreds or thousands of employees. Here are a few streamlined methods:
• Manual Search
Go to the OIG LEIE database and search by individual or entity name. While suitable for small teams, this is not scalable.
• Automated Exclusion Screening Services
These tools cross-reference your employee and vendor databases with the LEIE each month and flag any matches. Many also include checks against state Medicaid exclusion lists for comprehensive compliance.
• Integrate with HR and Vendor Systems
Some HR software and vendor management systems offer built-in OIG exclusion check capabilities, saving time and reducing human error.
Best Practices for OIG Exclusion Compliance
To fully implement an effective monthly exclusion check process, consider the following tips:
- Document Each Check: Maintain thorough records of monthly checks, including date, method, and results.
- Cover All Personnel: Screen not only employees but also contractors, temporary staff, volunteers, and vendors.
- Include State Exclusion Lists: Some states maintain their own exclusion databases. A comprehensive check should include both federal and applicable state lists.
- Follow Up Promptly: If a match is found, investigate immediately. Terminate relationships with excluded parties and consider self-disclosure to the OIG if necessary.
- Train Your Team: Make sure HR, compliance, and legal teams understand the importance of exclusion checks and how to conduct them.
Final Thoughts
Healthcare organizations must be proactive in protecting themselves from the legal, financial, and reputational risks associated with excluded individuals and entities. Monthly OIG exclusion checks are a straightforward but essential part of any robust compliance program.
Automating the process where possible, staying informed on regulatory updates, and documenting each step can help ensure your organization stays on the right side of the law — and keeps patient care and integrity at the center of operations.