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OIG Enforcement & Civil Money Penalties

OIG enforcement is the reason exclusion screening exists. Every Civil Money Penalty settlement, every provider self-disclosure, every state Medicaid Fraud Control Unit case starts from the same statutory framework: a person or entity on the LEIE, SAM, or a state exclusion list was paid with federal healthcare dollars — and the payer is on the hook. This hub tracks how the enforcement apparatus actually works in practice: who investigates, what penalties land, how the OIG has been applying 42 CFR 1003 over the last five years, and what the settlement record tells compliance officers about their real risk exposure.

What this guide will cover

  • The OIG’s enforcement authority under 42 CFR 1003 and Section 1128A of the SSA
  • CMP calculation methodology — per-item fines, trebled damages, exclusion add-ons
  • How Corporate Integrity Agreements are structured and when they trigger
  • State Medicaid Fraud Control Unit coordination with federal OIG
  • Settlement patterns by sector: hospitals, pharmacies, home health, behavioral health
  • Self-disclosure outcomes vs. forced-disclosure outcomes
  • What five years of settlement data (2020–2025) reveals about enforcement priorities

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The founders of Exclusion Screening — Paul Weidenfeld (former DOJ National Health Care Fraud Coordinator) and Robert Liles — built the enforcement framework that drives these cases. If you’re evaluating your exclusion screening program against real enforcement risk, we can help.

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  • OIG, SAM & state exclusion lists
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