What the OIG Exclusion List Actually Is
The Office of Inspector General (OIG) of the US Department of Health and Human Services maintains a List of Excluded Individuals and Entities (LEIE). This list contains individuals and organisations that are prohibited from participating in any federally funded healthcare program — including Medicare, Medicaid, CHIP, and VA programs.
Exclusions happen for reasons including healthcare fraud, patient abuse, felony convictions related to healthcare delivery, and licence revocations. Once excluded, an individual cannot be employed, contracted, or otherwise engaged in any capacity that provides services paid for by federal healthcare programs.
Critical point: The prohibition isn't just on direct patient care. An excluded individual cannot be employed in any capacity where their salary is funded — even partially — by a federal healthcare program. That includes administrative, billing, and management roles.
Why This Matters Specifically for Staffing Agencies
Healthcare staffing agencies are in a uniquely exposed position. You place workers across multiple client facilities — hospitals, homecare providers, physician practices — many of which bill Medicare or Medicaid. If you place an excluded individual at any of those facilities, both you and the facility can face civil monetary penalties.
The penalties are severe: up to $20,000 per item or service furnished by an excluded individual, plus three times the amount of the improper claim. Repeated violations can result in permanent exclusion of your agency from federal programs — which for most healthcare staffing businesses is effectively a shutdown.
Ignorance is not a defence. The OIG's position is clear: if you failed to check, you failed in your duty. The list is publicly available and free to search.
"Ignorance of an exclusion is not a defence. Facilities and agencies are expected to check before every placement — not just at hire."— OIG guidance on exclusion screening obligations
How Often Do You Need to Check?
This is where many agencies get it wrong. OIG guidance — and the policies of most state Medicaid programs — require monthly screening of all employees and contractors, not just a one-time check at onboarding.
The reason: exclusions happen continuously. A worker who was clean at hire can be added to the LEIE list at any time. If you only check at onboarding, you have no way of knowing whether someone currently on your roster has been excluded since they joined.
| Screening point | Required? | Notes |
|---|---|---|
| Pre-hire / pre-placement | ✔ Yes | Before any placement at a federal program facility |
| Monthly — all active staff | ✔ Yes | OIG and most state Medicaid programs require this |
| Before contract renewal | ✔ Yes | Treat renewals as new placements for screening purposes |
| After a gap in placement | ✔ Yes | Re-screen before any return-to-work placement |
| One-time at onboarding only | ✗ Not sufficient | Does not meet OIG guidance or most state requirements |
What the Check Actually Involves
The OIG provides a free search tool at oig.hhs.gov/exclusions. You can search by name, entity name, or NPI number. For individual workers, you need to search by both name and date of birth to reduce false positives from common names.
Beyond the federal LEIE, you should also check:
- State Medicaid exclusion lists — each state maintains its own exclusion list, and an individual may be excluded by a state without appearing on the federal list.
- SAM.gov (System for Award Management) — for any agency working with federally funded programs beyond Medicare and Medicaid.
- State licensing boards — a nurse whose licence has been revoked in one state may still be licensed in another. Cross-state checks matter.
Name matching complexity: Common names generate false positives. Always match on full legal name plus date of birth. Document every search result — including negative results — as evidence that the check was performed.
Documentation — What You Need to Keep
Running the check isn't enough. You need to be able to prove you ran it, when you ran it, and what the result was. In an audit or investigation, your documentation is your defence.
For every OIG exclusion check, document:
- Full legal name searched and date of birth used
- Date and time the search was conducted
- Which databases were searched (federal LEIE, state Medicaid list, SAM.gov)
- Result — clear or match found
- Name of the staff member who conducted the search
- Any follow-up actions taken if a potential match was found
This documentation needs to be retained for at least six years — longer in some states. It needs to be retrievable on demand. A spreadsheet is technically possible but creates significant audit risk — version control, access tracking, and retrieval speed all become problems at scale.
How a Platform Handles This Automatically
Manual OIG checks on a spreadsheet work when you have ten workers. At fifty workers checked monthly, that's 600 individual searches per year — all requiring documentation. At 200 workers, it's 2,400. This is where manual processes break down and where automated screening becomes not optional but operationally necessary.
Every platform Staffinc builds includes automated OIG exclusion screening as a core compliance module:
- Monthly batch screening of every active worker against the federal LEIE and configured state lists
- Automatic alerts when a potential match is found — flagged for human review before the next placement
- Full audit log of every search result, timestamped and tied to the worker's compliance record
- Pre-placement screening triggered automatically when a new shift is assigned
- Exportable compliance reports for facility audits and contract renewals
Built in, not bolted on: OIG screening isn't an add-on module in Staffinc platforms — it's integrated into the placement workflow. A worker flagged as a potential match cannot be placed until the flag is cleared by an authorised user.
What to Do If You Find a Match
Finding a potential match doesn't automatically mean the worker is excluded — common names generate false positives regularly. Your response process matters:
- Immediately pause any upcoming placements for that worker.
- Confirm the match using full legal name, date of birth, and NPI number.
- If confirmed, remove the worker from all active placements immediately.
- Notify the affected client facilities — they have their own reporting obligations.
- Document every step of the response with timestamps.
- Consult legal counsel — self-disclosure to the OIG may be advisable depending on whether any claims were submitted during the exclusion period.