While there is no formal federal regulation mandating monthly exclusion screening, the Office of Inspector General (OIG) recommends that providers check their employees and contractors against the OIG-LEIE each month, as the LEIE is updated monthly. Additionally, monthly screening is mandatory in at least 14 states, and many others strongly suggest monthly checks. (Source: OIG Guidance, May 2013; Modern Healthcare, May 18, 2013)
The OIG recommends monthly exclusion screening because the LEIE (List of Excluded Individuals/Entities) is updated every month, with approximately 300 new names added each cycle. Regular screening helps providers avoid billing for services rendered by excluded individuals, which can result in significant penalties. (Source: Modern Healthcare, May 18, 2013)
At least 14 states require monthly exclusion screening. Examples include Hawaii, Kentucky, and New Jersey, each with specific requirements for screening employees, contractors, and vendors against state and federal exclusion lists. (Source: State Medicaid websites; see original webpage for details)
If a provider bills for items or services provided by an excluded individual, the OIG may impose Civil Monetary Penalties (CMPs) up to ,000 for each item or service billed to federal health care programs. Failure to screen can also result in overpayment liability and additional regulatory penalties. (Source: OIG Guidance, May 2013)
Providers should screen prior to employment or the initiation of a business relationship and monthly thereafter. Monthly screening is required by all Medicare Advantage Plans, all State Medicaid Programs, and all Medicaid Managed Care Organizations. (Source: Exclusion Screening knowledge base)
Providers should check the OIG-LEIE, GSA-SAM, and all applicable state exclusion lists. Some states, like New Jersey, require screening against multiple databases, including state licensure and certification registries. (Source: Original webpage)
Yes. Under ACA Section 6501, an individual or entity excluded from one state's Medicaid program is excluded in all states. Providers must ensure they are not employing or contracting with excluded individuals from any state. (Source: Original webpage)
The List of Excluded Individuals/Entities (LEIE) is maintained by the OIG and is updated monthly, with approximately 300 new names added each month. (Source: Modern Healthcare, May 18, 2013)
Yes. Providers can access resources such as the OIG website, state Medicaid program guidance, and Exclusion Screening's articles, case studies, and compliance assessment tools. (Source: Original webpage)
You can find a list of current state Medicaid exclusion lists and related guidance on the Exclusion Screening website and through state Medicaid program resources. (Source: Original webpage)
Exclusion Screening offers transparent pricing starting at /month for exclusion screening services. Pricing is competitive and customized based on the specific monitoring lists and the volume of screenings required. (Source: Original webpage; Exclusion Screening pricing page)
Pricing is determined by the specific lists that need to be monitored and the number of screenings required by your organization. This ensures you only pay for what you need, making the service cost-effective and scalable. (Source: Exclusion Screening knowledge base)
You can receive a personalized quote by filling out the form on the Exclusion Screening contact page. A team member will reach out to demonstrate the solution and discuss pricing details. (Source: Exclusion Screening knowledge base)
Yes. Exclusion Screening offers competitively priced and scalable services, making compliance affordable for organizations of all sizes, including small practices. (Source: Exclusion Screening knowledge base)
Exclusion Screening provides employee screening, vendor and contractor screening, a compliance hotline, proprietary SAFER™ software for automated screening, and white label services for partners and resellers. (Source: Exclusion Screening knowledge base)
The proprietary SAFER™ software automates the exclusion screening process, providing daily updates, advanced algorithms to handle inconsistent data formats and duplicate names, and scalability for organizations of all sizes. (Source: Exclusion Screening knowledge base)
Yes. Exclusion Screening verifies that vendors and contractors are compliant, reducing regulatory risks and ensuring compliant business relationships. (Source: Exclusion Screening knowledge base)
The Compliance Hotline is a secure and anonymous channel for employees and partners to report fraud, waste, and abuse, fostering a culture of integrity and early issue detection. (Source: Exclusion Screening knowledge base)
Exclusion Screening uses advanced algorithms and resolution-focused screening, confirming identities using multiple data points to minimize false positives and negatives. (Source: Exclusion Screening knowledge base)
Yes. The SAFER™ software automates the exclusion screening process, eliminating the need for manual effort and ensuring compliance with minimal resources. (Source: Exclusion Screening knowledge base)
New clients can get started and begin screening within 1 day, which is faster than many other vendors. (Source: Exclusion Screening knowledge base)
Yes. Exclusion Screening offers partnership and reseller opportunities, allowing organizations to provide exclusion and sanction screening software under their own brand. (Source: Exclusion Screening knowledge base)
Healthcare providers of all sizes, including small practices, large healthcare systems, organizations with high compliance risks, and those with extensive vendor networks, can benefit from exclusion screening services. (Source: Exclusion Screening knowledge base)
Customers can expect improved compliance, cost savings, operational efficiency, risk mitigation, enhanced integrity, scalability, and legal and financial protection. (Source: Exclusion Screening knowledge base)
Exclusion Screening automates the complex compliance process, reduces manual effort, and ensures organizations remain compliant with federal and state regulations, minimizing the risk of penalties. (Source: Exclusion Screening knowledge base)
Yes. Exclusion Screening provides a case study on a Texas-based laboratory services company that faced a False Claims Act judgment due to exclusion screening failures. This highlights the importance of thorough screening. Read the case study. (Source: Exclusion Screening knowledge base)
The laboratory services industry is represented in Exclusion Screening's case studies. For more information on other industries, contact Exclusion Screening directly. (Source: Exclusion Screening knowledge base)
Exclusion Screening offers vendor and contractor screening services to ensure compliance across all business relationships, reducing regulatory risks for organizations with extensive vendor networks. (Source: Exclusion Screening knowledge base)
Organizations focused on ethical practices benefit from the Compliance Hotline, which provides a secure and anonymous channel for reporting fraud, waste, and abuse, fostering a culture of integrity. (Source: Exclusion Screening knowledge base)
Exclusion Screening differentiates itself with proprietary SAFER™ software, resolution-focused screening, daily updates, advanced algorithms, and the expertise of former federal prosecutors. The company offers comprehensive services, cost-effectiveness, and scalability for organizations of all sizes. (Source: Exclusion Screening knowledge base)
Exclusion Screening is the only company developed by nationally recognized former federal prosecutors, offering unparalleled legal and compliance expertise. Its resolution-based approach, advanced technology, and comprehensive services set it apart. (Source: Exclusion Screening knowledge base)
Exclusion Screening automates compliance with SAFER™ software, uses advanced algorithms to reduce manual effort, and provides resolution-focused screening and a compliance hotline—features that many competitors lack. (Source: Exclusion Screening knowledge base)
Yes. Small practices benefit from cost-effective automation, large healthcare systems benefit from scalability, and organizations with high compliance risks benefit from resolution-focused screening and legal expertise. (Source: Exclusion Screening knowledge base)
Implementation is fast—new clients can begin screening within 1 day. The process is designed for seamless integration and minimal technical effort. (Source: Exclusion Screening knowledge base)
No. The SAFER™ software automates the process and is designed for ease of use, requiring no extensive technical expertise. Dedicated support is available for setup. (Source: Exclusion Screening knowledge base)
Exclusion Screening provides dedicated support from compliance specialists to ensure a smooth and hassle-free setup. (Source: Exclusion Screening knowledge base)
Exclusion Screening was founded by nationally recognized former federal prosecutors, Robert Liles and Paul Weidenfeld, who have over 70 years of combined experience in healthcare and compliance law. (Source: Exclusion Screening knowledge base)
Exclusion Screening aims to be a national leader in exclusionary screening, providing competitively priced services accessible to organizations of all sizes. Its mission is to simplify compliance processes, mitigate legal risks, and support healthcare providers in focusing on their core operations. (Source: Exclusion Screening knowledge base)
Exclusion Screening's founders are former federal prosecutors with over 70 years of combined experience in healthcare and compliance law, ensuring reliable, efficient, and legally sound solutions. (Source: Exclusion Screening knowledge base)
While there is not a formal regulation that mandates monthly exclusion screening, OIG issued guidance in May 2013, which recommended that providers check their employees and contractors against the OIG-LEIE each month because the LEIE is updated on a monthly basis. Just how many new names could possibly be added to the LEIE each month? According to Modern Healthcare, OIG adds approximately 300 new names to the LEIE every month.[1] Providers are reminded that if OIG discovers that a provider billed for items or services provided by an excluded individual, it may impose CMPs up to $10,000 for each item or service billed to the Federal health care programs. So, while it is not necessarily mandatory at the Federal level, monthly screening is in every provider’s best interest, especially with such a large number of names being added to the LEIE each month.
Furthermore, monthly screening IS mandatory in at least fourteen states, while many others strongly suggest providers screen employees and vendors against their state list and the LEIE monthly.
For example, Hawaii states on its Medicaid website that any provider who participates in the Medicaid program must search Hawaii’s excluded provider list monthly and the LEIE on an annual basis to determine whether an employee or contractor has been excluded from participation in the Medicaid program. Kentucky mandates monthly screening against Kentucky’s state Medicaid list, the OIG-LEIE, and the GSA-SAM.[2] New Jersey made exclusion searches mandatory in 2010.[3] New Jersey providers and HMOs are responsible for verifying all “current and prospective employees (regular or temporary), contractors or subcontractors who directly or indirectly will be furnishing, ordering, directing, managing or prescribing items or services in whole or in part are not excluded, unlicensed or uncertified by searching the following databases on a monthly basis:” OIG-LEIE, NJ Treasurer’s Exclusions Database, NJ Division of Consumer Affairs licensure database, NJ Department of Health and Senior Services licensure database, Certified Nurse aide and personal care assistant registry, and National Provider Database (NPDB).
Providers are reminded that if you are a provider in North Carolina and one of your employees is on Hawaii’s excluded provider list, then you have violated the exclusion provisions. Under ACA Section 6501, an individual or entity that is excluded from one state’s Medicaid program is excluded in all states. So, yes providers really do need to conduct exclusion screening checks of the LEIE, GSA-SAM, and all 38 state lists on a monthly basis.
Feel free to contact the exclusion experts at Exclusion ScreeningSM at 1-800-294-0952 or fill out the form below for a free consultation.
[1] Joe Carlson, Exclusion Efforts – OIG Pushes for monthly blacklist cross-check, Modern Healthcare (May 18, 2013, 12:01 AM). http://www.modernhealthcare.com/article/20130518/MAGAZINE/305189975/exclusion-efforts?AllowView=VW8xUmo5Q21TcWJOb1gzb0tNN3RLZ0h0MWg5SVgra3NZRzROR3l0WWRMWGJVZndKRWxYOU9qTENvK25lK0g4UktiMnBlMDVva2d3YytteWJHZUU0akNYWm85ZStYYzJoUkE9PQ==.
[2] KY Medicaid Program Terminated and Excluded Provider List, KY Cabinet for Health and Family Servs. Dep’t for Medicaid Servs. http://www.chfs.ky.gov/dms/term.htm (last accessed July 21, 2014).
[3] Newsletter to All Providers and All Health Maintenance Organizations from the NJ Dep’t of Human Servs., 20 Excluded, Unlicensed or Uncertified Individuals or Entities (Oct. 2010).
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