OIG Screening Readiness Resource
How strong is your exclusion-screening process?
An excluded worker on federally reimbursed services can create overpayment and civil monetary penalty exposure. Use this 10-point checklist to review your screening process and surface open practices.
Educational readiness resource only. It does not provide legal advice or determine compliance. Requirements vary by program, state, contract, facility, and role.
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The assessment covers screening cadence, applicable databases, state requirements, evidence retention, response policy, and staff training.
- 1Screen candidates who may furnish items or services payable, directly or indirectly, by a Federal health care program against the OIG List of Excluded Individuals/Entities (LEIE) before placement.
- 2Re-screen active placements against the LEIE each month as a risk-minimizing practice.
- 3Check SAM.gov when federal-award, state Medicaid, facility, customer, or contract rules require it.
- 4Identify and screen any applicable state Medicaid exclusion or termination lists in every state where you place staff.
- 5Record the search date, source, query details, result, and any identity-resolution steps for potential matches.
- 6Retain screening evidence for the period required by applicable program rules, state law, customer contracts, and your documented retention policy.
- 7Have a written exclusion response policy: what happens when a match is found, who is notified, and how placements are paused.
- 8Verify NPI status when an NPI is required for the applicable transaction, and verify licensure separately with the appropriate state source.
- 9Define how exclusion-screening results are handed off to the people making staffing decisions.
- 10Provide role-specific exclusion-screening and escalation training at onboarding and periodically thereafter.