ExclusionHQ

Monitoring

Monthly exclusion screening

Exclusion screening means checking every employee and contractor against the federal exclusion lists, and your state's Medicaid list, before they start and then on a schedule.

Which lists

  • The OIG exclusion list (the LEIE): federal health care program exclusions.
  • SAM.gov exclusions (federal debarments and exclusions from many agencies).
  • Your state's Medicaid exclusion or termination list, where the state keeps one. See state Medicaid exclusion lists.

How often

Federal law doesn't require providers themselves to check the LEIE (OIG says so in its 2013 guidance), but hiring an excluded person can bring civil monetary penalties, and OIG says screening each month best minimizes that risk because it updates the list monthly.

State Medicaid agencies must check the LEIE and the federal debarment list (now part of SAM.gov) no less than monthly (42 CFR 455.436), and in 2009 CMS told states to require providers to search OIG's list monthly. Many states now write monthly screening into their provider agreements.

What to keep

  • The date of each check and which lists (and which version of each) it used.
  • Everyone checked, and the result for each.
  • How every potential match was resolved, by whom and when.

Sources

Related

Monthly monitoring

Need this every month?

Save your roster once. ExclusionHQ re-checks it against the LEIE, SAM.gov and 20 state Medicaid lists whenever one updates, emails you when something changes, and keeps a dated audit report for every check. From $39 a month for up to 100 people.

Example · a dental office14 people
Day 1
SAM.gov updated14 people re-checked · 1 new to verify
Verify
Day 4
LEIE monthly file14 people re-checked · no changes
Day 9
A state list updated14 people re-checked · no changes
Day 30
Monthly receiptReport filed for the month

Questions

Is monthly screening required by law?

Not by federal statute or regulation for providers themselves: OIG says so. But employing an excluded person can lead to civil monetary penalties and repayment, OIG recommends monthly checks, state Medicaid agencies must check monthly (42 CFR 455.436), and many states require monthly screening in their provider agreements. Check your own state's agreement; this page is not legal advice.