What is the OIG Exclusion Screening List and why is it important?
The OIG Exclusion Screening List is a mandatory compliance requirement for healthcare providers and suppliers who participate in Medicare or Medicaid. It ensures that employees, vendors, contractors, and agents are not excluded from participation in federal and state healthcare programs. Screening helps organizations avoid severe penalties, including Civil Monetary Penalties (CMP) of up to ,000 per item or service and potential triple damages on claims submitted for payment. Source
Who is required to be screened against the OIG Exclusion List?
All employees, staff, vendors, contractors, and agents who provide items or services—directly or indirectly—payable by federal health care programs must be screened. This includes administrative, management, and support service providers, even if their services are not separately billable. Source
What types of vendors and contractors must be included in exclusion screening?
Examples include ambulance and transportation service providers, volunteers, IT solution providers, security technicians, medical equipment managers, food service workers, lab technicians, pharmacists, nurses (including those from staffing agencies), physician groups, billing or coding contractors, directors, administrators, and managers. Source
What information should be collected for employee exclusion screening?
To properly screen employees, you should collect and examine their Social Security Number (SSN), maiden names, any former names, and birthdate. This information helps ensure accurate and thorough screening. Source
What are the risks of not conducting exclusion screening?
Failure to conduct exclusion screening can result in Civil Monetary Penalties (CMP) of up to ,000 per item or service provided by an excluded individual or entity, and providers may be required to pay up to three times the total amount of claims submitted to Medicare. Source
How often should exclusion screening be performed?
Exclusion screening should be performed at least monthly to ensure ongoing compliance with federal and state requirements. Regular screening helps organizations avoid penalties and maintain eligibility for federal health care program participation. Source
Can providers rely on contractors or vendors to conduct their own exclusion screening?
Providers may rely on a contractor's or vendor's certification that they are conducting exclusion screening of their own employees and contractors. However, HHS-OIG recommends that providers validate this by requesting and maintaining screening documentation from the contractor or vendor. OIG Special Advisory Bulletin
What official guidance exists on exclusion screening requirements?
The HHS-OIG's 2013 Special Advisory Bulletin provides detailed guidance on the effect of exclusion from participation in federal health care programs and outlines provider responsibilities for screening. Read the Bulletin
Where can I find a step-by-step guide to OIG exclusions?
You can read the in-depth article "A Provider’s Guide to OIG Exclusions" on the Exclusion Screening website for a comprehensive overview of the process. Read the Guide
What is the financial fallout of screening failures?
Screening failures can result in significant financial penalties. For example, Exclusion Screening reports that million in penalties have been assessed due to screening failures. Download the report
How can Exclusion Screening help me create my exclusion screening list?
Exclusion Screening assists customers in evaluating and determining exactly who needs to be included in their monthly exclusion screening. Their experts can help you compile a comprehensive list of employees, vendors, and contractors. Source
What is the scope of an OIG exclusion action?
The scope is extremely broad. Excluded individuals are prohibited from furnishing administrative and management services payable by federal health care programs, even if not separately billable. This includes executive roles, IT, billing, accounting, staff training, and more. OIG Special Advisory Bulletin
What are some examples of roles that must be screened?
Roles include chief executive officer, chief financial officer, general counsel, director of health information management, director of human resources, physician practice office manager, and other administrative or management positions. OIG Special Advisory Bulletin
What documentation should providers maintain for exclusion screening?
Providers should maintain documentation of all screening activities, including records of employee, vendor, and contractor screenings, as well as any certifications or screening documentation provided by contractors or vendors. OIG Special Advisory Bulletin
What is the penalty for employing an excluded individual?
The penalty can be up to ,000 per item or service provided by an excluded individual, plus up to three times the amount claimed to Medicare. Source
How can I contact Exclusion Screening for help?
You can contact Exclusion Screening by calling 1-800-294-0952 or by filling out the contact form on their website. Contact Exclusion Screening
Where can I find more resources on exclusion screening?
Exclusion Screening provides a variety of resources, including articles, guides, and compliance assessments, available on their Resources page. Resources
What is the starting price for exclusion screening services?
Exclusion Screening offers transparent pricing starting at /month for exclusion screening services. View pricing
Which exclusion lists are included in Exclusion Screening’s package?
Exclusion Screening screens employees and vendors against the OIG-LEIE, GSA-SAM, and all available state Medicaid exclusion lists. Source
Features & Capabilities
What features does Exclusion Screening offer?
Exclusion Screening offers employee screening, vendor and contractor screening, a compliance hotline, proprietary SAFER™ software for automated screening, and white label services for partners and resellers. Learn more
How does the SAFER™ software improve exclusion screening?
The SAFER™ software automates the exclusion screening process, provides daily updates, uses advanced algorithms to handle inconsistent data and duplicate names, and reduces false positives and negatives. It is scalable for organizations of all sizes. Source
What is resolution-focused screening?
Resolution-focused screening confirms identities using multiple data points, reducing false positives and negatives. This approach minimizes compliance risks and ensures thorough checks. Source
Does Exclusion Screening offer a compliance hotline?
Yes, Exclusion Screening provides a secure and anonymous compliance hotline for reporting fraud, waste, and abuse, fostering a culture of integrity and early issue detection. Learn more
How quickly can Exclusion Screening be implemented?
New clients can get started and begin screening within 1 day, which is faster than many other vendors. The process is seamless and supported by compliance specialists. Source
What makes Exclusion Screening different from competitors?
Exclusion Screening is the only company developed by nationally recognized former Federal prosecutors. It offers proprietary SAFER™ software, resolution-focused screening, comprehensive services, and a commitment to cost-effectiveness and scalability. Source
What is included in Exclusion Screening’s white label services?
White label services allow organizations to provide exclusion and sanction screening software under their own brand, leveraging Exclusion Screening’s technology and expertise. Learn more
How does Exclusion Screening address the complexity of compliance?
Exclusion Screening automates the burdensome and complex process of federal and state exclusion screening, ensuring compliance with minimal effort and maximum accuracy. Source
How does Exclusion Screening help with vendor and contractor compliance?
Exclusion Screening verifies that vendors and contractors are compliant, reducing regulatory risks and ensuring compliant business relationships. Learn more
What is the business impact of using Exclusion Screening?
Customers can expect improved compliance, cost savings, operational efficiency, risk mitigation, enhanced integrity, scalability, and legal/financial protection. Source
How does Exclusion Screening support organizations with high compliance risks?
Exclusion Screening emphasizes resolution-focused screening and thorough checks to help organizations avoid penalties like Civil Monetary Penalties (CMP) through proactive compliance measures. Source
What industries are represented in Exclusion Screening’s case studies?
Exclusion Screening’s case studies include the laboratory services industry, with a notable example involving a Texas-based laboratory services company and the impact of a False Claims Act judgment. Read the case study
Can you share a specific customer success story?
Yes, Exclusion Screening details a case study involving a Texas-based laboratory services company that submitted false claims, highlighting the importance of thorough exclusion screening and compliance. Read the case study
What is Exclusion Screening’s pricing model?
Pricing is competitive and customized based on the specific monitoring lists and volume of screenings required. Organizations only pay for what they need, making the service cost-effective and scalable. Contact for quote
Who is the target audience for Exclusion Screening?
The target audience includes healthcare providers (small practices, large healthcare systems), compliance officers, risk managers, legal teams, operational managers, and organizations with extensive vendor and contractor relationships. Source
What is Exclusion Screening’s vision and mission?
Exclusion Screening’s vision is to be a national leader in exclusionary screening, providing competitively priced services accessible to organizations of all sizes. The mission is to simplify compliance, mitigate legal risks, and support healthcare providers in focusing on core operations. Source
New ReportScreening Failures & Their Financial Fallout — $26M in penalties and how to avoid them. Download the report →
As many healthcare providers and suppliers have painfully learned over the last year, federal and state law enforcement agencies, along with many of the contractors with whom they work, are actively conducting audits of Medicare and Medicaid claims submitted to the government for coverage and payment
One of the least understood mandatory obligations applicable to virtually every healthcare provider and supplier who accepts Medicare or Medicaid is the requirement that all participating providers are REQUIRED to screen more than just their staff. Instead, they must also screen contractors, vendors, and agents to ensure that they and their employees have not been excluded from participation in federal and state healthcare programs. The fact that these individuals and entities must be screened through literally dozens of federal and state exclusion databases further complicates this mandate.
II. Broad Scope of OIG Exclusion Action
Importantly, the scope of an exclusion action is extremely broad. The Department of Health and Human Services, Office of Inspector General (HHS-OIG) has taken the position that if a vendor, contractor or supplier of administrative, management or support services has been excluded from participating in the Medicare or Medicaid programs, they are effectively barred from working with most health care provider and supplier entities. As HHS-OIG writes:
“Excluded persons are prohibited from furnishing administrative and management services that are payable by the Federal health care programs. This prohibition applies even if the administrative and management services are not separately billable. For example, an excluded individual may not serve in an executive or leadership role (e.g., chief executive officer, chief financial officer, general counsel, director of health information management, director of human resources, physician practice office manager, etc.) at a provider that furnishes items or services payable by Federal health care programs. Also, an excluded individual may not provide other types of administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to Federal health care programs.”[1]
At Exclusion ScreeningSM, we realize that compiling a list of all employees, vendors, and contractors can be a daunting task. That’s why we help our customers evaluate and determine exactly who needs to be included during their monthly Exclusion Screening. For an in-depth guide to OIG Exclusions, read our article, A Provider’s Guide to OIG Exclusions.
III. Creating Your OIG Exclusion Screening List
A partial listing of the parties you are required by law to screen include:
All employees and Staff: To properly screen you should be sure to examine (or submit this information to us so we can conduct the screens for you):
1. SSN.
2. Maiden names.
3. Any former names.
4. Birthdate.
Vendors, Contractors, and Agents: You MUSTscreen vendors that provide items or services directly OR indirectly that are payable in whole or in part by the Federal health care programs[2]
Some potential vendors that must be included on your list:
1. Ambulance and other Transportation Service Providers.
2. Volunteers.
3. IT Solution Providers.
4. Security Technicians.
5. Medical Equipment Managers.
6. Food Service Workers.
7. Lab Technicians.
8. Pharmacists.
9. Nurses and other Individuals Provided by Staffing Agencies.
10. Physician Groups that Provide Emergency Room Coverage.
11. Billing or Coding Contractors.
12. Directors.
13. Administrators.
14. Managers.
IV. Contractors and Vendors
When it comes to contractors and vendors, HHS-OIG offers some interesting guidance in its 2013 Special Advisory. The OIG gives providers two options: (1) providers themselves may screen their contractors’ or vendors’ employees;[3] or (2) a provider may rely on a contractor’s or vendor’s certification that the contractor or vendor is conducting screening of its own employees and contractors. Note that HHS-OIG recommends that the provider validate that the contractor is conducting such screening on behalf of the provider. One way providers can validate this information is by requesting and maintaining screening documentation from the contractor.[4]
V. Screen for Exclusions: Avoid CMPs!
Screening this list can seem like a daunting task, but not doing so can create a world of hurt. The phrase “leave no stone unturned” couldn’t be more appropriate in this case. An effective compliance policy demands that providers employ comprehensive screening practices. Although the process may seem arduous, the risks providers face, if they do not screen, are dire. The Civil Monetary Penalty (CMP) for any item or service provided by an excluded individual or entity is up to $10,000. On top of CMPs, the providers may be required to pay up to three times the total amount of claims submitted to Medicare.
Considering the hefty liabilities tacked on for merely employing even one excluded individual, it’s easy to see that making the effort to properly screen for exclusions pays for itself. If you’re worried that your organization isn’t screening the right individuals and entities, the exclusion experts at Exclusion ScreeningSM are happy to help you create your employee and vendor list. Feel free to contact us at 1-800-294-0952 or fill out the form below.
Paul S Weidenfeld
Paul Weidenfeld is a former federal healthcare fraud prosecutor and Department of Justice National Health Care Fraud Coordinator. His principal area of practice is healthcare fraud and abuse and the Federal False Claims Act, and he has represented providers and individuals in healthcare matters since leaving government in 2006. Mr. Weidenfeld also has an extensive litigation background that includes numerous trials and appeals and appearances before the United States Supreme Court, the Federal 5th Circuit Court of Appeals, and the Louisiana Supreme Court.
