Frequently asked questions | SAFER PLUS
FAQ
Everything you need to know about the new SAFER™ platform. Find answers to commonly asked questions about features, your account, and getting started.
Billing
We’ve updated our business mailing address to ensure more efficient processing our physical mail. The new address for payments by check is:
Exclusion Screening LLC
1763 Columbia Rd NW Ste 175
PMB 182797
Washington, District of Columbia 20009-2891 US
Roster/File upload and management, Report Access, SAFER Plus use
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.
As often as you need to! You will have access to your employee list at all times and may update it anytime at no additional charge.
Of course! We want to make sure new employees are screened immediately so we will screen all new hires at no additional charge.
At Exclusion Screening, we, along with OIG, strongly recommend screening employees on a monthly basis.
There is no specific deadline for uploading your employee or vendor files.
You have access to your employee list at all times and can update it or upload files as often as you need to at no additional charge.
If you hire a new employee in the middle of the month, you can upload their information right away, and the system will screen the new hire immediately. While there is no hard deadline for the upload itself, you should ensure your rosters are consistently updated so that all staff and vendors are being screened on a regular monthly basis.
Yes, you should continue to screen the exact same list every single month.
Even if your roster of employees and vendors has not changed, a person’s exclusion status is not static and can change at any time.
There are several reasons why monthly screening is critical for companies with low turnover like, status changes after hire, reporting delays, employees will not tell you, and compounding financial risk
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.
Report Analysis
A red match/record/individual indicates a confirmed match or a “hit”. This means the individual is officially excluded from participating in federal or state healthcare programs (such as Medicare, Medicaid, TRICARE, etc.). The government has deemed this person an unacceptable risk to patient safety or the financial integrity of healthcare programs, often due to a history of fraud, patient abuse, licensure revocations, or drug offenses. If you have a confirmed excluded individual, federal and state programs will not pay for any goods or services furnished, directly or indirectly, by this person
You must immediately stop the individual from providing any services that are billed directly or indirectly to federal or state healthcare programs. Continuing to employ or contract with them exposes your practice to massive Civil Monetary Penalties (up to $24,164 per claim), overpayment liabilities, and even False Claims Act or criminal liability.
“Resolving Exclusion Violations through the OIG Self-Disclosure Protocol”. This article details the “3-headed liability monster” of overpayments, penalties, and False Claims Act liability, and provides a step-by-step guide on how to successfully self-disclose the violation to the OIG.
To read more in-depth about this exact scenario, the sources provide the following articles that you should review: “I Have a Confirmed Exclusion What are my Options” This article outlines the immediate steps to take, the strict payment prohibitions, the rare exceptions for ongoing employment, and how to calculate damages.
It is common to find individuals on a state exclusion list but not on the federal OIG LEIE for three main reasons:
Reporting Failures: State agencies frequently fail to report their exclusions to the OIG in a timely manner, or sometimes fail to report them at all.
Despite these gaps, employing someone on any state list still exposes your practice to severe overpayment liabilities and Civil Money Penalties.
For more detailed information on these discrepancies, you can reference the article titled “Who Is to Blame for Gaps in OIG and State Exclusion Lists? What Is the Impact on Providers?”
State-Specific Offenses: States can exclude providers for violating state laws that do not qualify for a federal exclusion.
Processing Delays: It can take the OIG several months to formally add a state-reported exclusion to the federal list.
You should absolutely consider both state and federal exclusions, rather than relying solely on federal lists. In our article “Current States With a Separate Medicaid Exclusion List,” Section 6501 of the Affordable Care Act (ACA) mandates that if a provider is excluded from participating in one state’s Medicaid program, they are effectively excluded from participating in all fifty states. Furthermore, states often exclude providers for infractions based on state law—such as failing to pay state taxes, defaulting on state loans, or having state-specific licensure issues—that do not meet the criteria for a federal exclusion and will not appear on the federal OIG-LEIE database. Therefore, to fully mitigate the risk of overpayment liability and civil monetary penalties, it is highly recommended that providers regularly screen their employees and contractors against the federal LEIE and GSA-SAM databases, as well as all available state Medicaid exclusion lists.
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:
- Office of Inspector General – List of Excluded Individuals and Entities (OIG-LEIE)
- General Services Administration – System for Award Management (GSA-SAM)
These two federal databases are considered foundational for compliance, as they identify individuals and entities excluded from participation in federally funded healthcare programs and federal contracting.
For organizations requiring a more comprehensive risk mitigation approach, the SAFER database expands screening to include all available State Medicaid Exclusion Lists. Because state-level exclusions are not always captured in federal databases, incorporating these lists provides an additional layer of protection and reduces exposure to state-specific enforcement actions.For a detailed analysis of the distinctions between federal and state exclusion lists—and the compliance implications of each—please refer to the article: “OIG Exclusion and State Exclusion Lists: Which Exclusion Lists Need to Be Screened? What Is the Difference Between Them?”
No payment will be made by any Federal health care program for any item or services furnished, ordered or prescribed by an excluded individual or entity. The exclusion rule applies regardless of who submits the claim and it applies to all administrative and management services, even if they are not separately billable. It also applies to any vendor that an individual or entity contracts with, if the individual or entity knows or should know the vendor or person is excluded.
The exclusion provision encompasses direct and indirect patient care; it applies, but is not limited to: doctors, nurses, pharmacists, laboratory technicians, medical transportation services, accountants, administrators, and volunteers.
OIG has authority under the Civil Monetary Penalties Law (CMPL) to impose Civil Monetary Penalties (CMPs), assessments, and program exclusions against anyone who submits any false, fraudulent, or other improper claim to the Federal health program for payment. OIG has the power to impose CMPs of up to $10,000 for each claimed item or service furnished by an excluded individual or entity. The individual or entity could also be subject to an assessment of up to three times the amount claimed for each item or service and could face exclusion from the Federal health care program.
Dep’t of Health and Human Servs. Office of the Inspector Gen., Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs, 6–7 (May 8, 2013).
Related Resources
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