Frequently Asked Questions

Exclusions are final administrative sanctions imposed by the Office of Inspector General for the Department of Health and Human Services (HHS/OIG, or simply OIG) that bar individuals and entities from participating in Federal and State health care programs such as Medicare, Medicaid, CHIPs, and any other program that receives federal funding. Federal programs are prohibited from paying for items or services provided by excluded parties, and providers that employ or contract with them risk the imposition of civil money penalties and significant overpayments liability. In addition to the authority to impose exclusions, OIG is authorized to enforce compliance with exclusion regulations through civil money penalties and overpayments.

Providers should screen prior to employment or to the initiation of a business relationship and monthly thereafter. Monthly screening makes sense because a person’s exclusion status is always subject to change. It is required by all Medicare Advantage Plans, all State Medicaid Programs, and all Medicaid Managed Care Organizations. In addition, CMS and the OIG have equivocally expressed its support, and the OIG has linked a failure to screen with overpayment and CMP liability.

Providers are responsible for ensuring the exclusion status of all employees, vendors and contractors that provide items or services, directly or indirectly, in whole or in part, that are payable by federal health care programs. This is not limited to direct billers, and examples of services identified by the OIG include the following: transportation service providers, administrative services, medical equipment suppliers, billers and coders pharmacists, etc. When in doubt as to who should be screened, providers may want to consider that the OIG has stated that civil penalty liability is ‘greatest for those persons that provide items or services integral to the provision of patient care.’

OIG-LEIE updates its list monthly, while GSA-SAM and state exclusion lists vary. We automatically update our lists each month to ensure that our clients’ employees and vendors are screened against the most up-to-date databases.

Exclusion Screening conducts checks against both federal and state exclusion databases, depending on the subscription level selected. We think it is critical to screen employees and vendors against OIG-LEIE, GSA-SAM, and all of the state Medicaid exclusion lists available.

Under the basic subscription, screenings are performed against the two primary federal exclusion databases: the Office of Inspector General – List of Excluded Individuals/Entities (OIG-LEIE), the General Services Administration – System for Award Management (GSA-SAM), and your choice of one state Medicaid database.

Employing or contracting with an excluded individual carries severe consequences. The OIG may impose civil monetary penalties of up to $100,000 for each item or service furnished by the excluded individual, plus treble damages (three times the amount claimed). Providers may also face liability under the False Claims Act, which can result in additional penalties and damages. If an excluded individual is identified, the provider should immediately remove that person from any role involving federal health care program work, conduct an internal investigation to determine the scope of the exposure, and consider self-reporting to the OIG through the Self-Disclosure Protocol. Prompt action and voluntary disclosure can significantly reduce the financial and legal consequences.

Our Basic plan starts at $30 per month and our Premium plan starts at $40 per month, each covering up to 100 screens. Pricing scales based on the size of your roster and the level of service you need. To learn more about which plan is right for your organization, schedule a demo with our team.

Getting started is fast and straightforward. After you sign up, simply send us your employee and vendor roster and our team will configure your account. Screening typically begins within a few business days of receiving your data. There is no lengthy implementation process or complex software installation—our platform is cloud-based and ready to go as soon as your roster is loaded.

SAFER™ is our proprietary exclusion screening software built specifically for healthcare compliance. It screens your employees, contractors, and vendors against OIG-LEIE, GSA-SAM, all 42 available state Medicaid exclusion databases, and the Social Security Administration Death Master File (SSADMF). The platform automatically updates whenever the underlying databases change, so your organization is always screened against the most current data—without any manual effort on your part.

Yes. In addition to employees, we screen all contractors, vendors, and third-party service providers who are involved in delivering items or services payable by federal health care programs. The OIG has made clear that exclusion screening obligations extend beyond direct employees to include any individual or entity in your supply chain. Our platform makes it easy to manage and screen your entire workforce and vendor network from a single dashboard. Learn more about our contractor and vendor screening services.