Exclusion screening for community health centers, FQHCs, and tribal health programs
A community health center runs medical, dental, and behavioral health care under one roof, and every person who touches a Medicare or Medicaid claim has to be clear of the exclusion lists. Two health centers that self-disclosed to OIG in 2020 paid $47,611 and $102,245 for a single excluded employee each. We screen your clinicians, enabling services staff, contractors, and board members every month against the federal exclusion lists and every state Medicaid list, and our specialists resolve any match before it reaches you.
Why health centers are exposed
- One organization, many service lines. A health center may employ physicians, dentists, hygienists, behavioral health clinicians, pharmacists, and community health workers. Each group has its own licensing board and hiring path, and it’s easy for one of them to fall outside the screening routine.
- Medicaid exclusions count on their own. A person can be excluded by a state Medicaid program without appearing on the federal OIG list. A health center that bills Medicaid and checks only the federal lists leaves that gap open. Grant compliance and exclusion screening are separate checks. Health centers that receive federal grants must make sure the contractors they hire with grant funds are not suspended or debarred. The usual way to do that is a SAM check. That check covers the contractor, not its staff or yours, and it is no substitute for checking the OIG list and state Medicaid lists.
- Tribal programs bill the same programs. If your tribal health program or urban Indian organization bills Medicare or Medicaid, those programs won’t pay for items or services furnished by an excluded person, and the same “knew or should have known” standard applies as for any other provider.
Who to screen
- Physicians, nurse practitioners, physician assistants, and nurse-midwives
- Dentists, hygienists, and dental assistants
- Behavioral health clinicians and substance use counselors
- Pharmacists and pharmacy technicians, including staff at contract pharmacies
- Nurses and medical assistants
- Community health workers, patient navigators, and outreach and enrollment staff
- Front desk, billing, and coding staff
- Locum tenens, volunteer clinicians, and providers working under contract
- Board members, the CEO, and other managing employees
The group health centers forget most often is contracted and volunteer clinicians. A locum dentist or a volunteer physician who sees patients at your site furnishes services you bill, whether or not they appear in your HR system.
“We do not have to devote hours of staff time to do the required GSA screenings and can focus on other important workflows.”
Verified user in Health, Wellness and Fitness (small business), 5-star review on G2
About 1,000 healthcare organizations trust us with their screening every month, including many community health centers and tribal health programs. Exclusion Screening was founded by former federal prosecutors Paul Weidenfeld and Robert Liles.
How we handle health center screening
- Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, covering clinical, enabling services, and administrative staff in one file.
- Identity verification before anything is flagged. We confirm identity with Social Security number, date of birth, NPI, or license data before calling something a match, so a common name in your community doesn’t turn into a false alarm.
- Our specialists resolve matches. When a name comes back, one of our trained specialists works it to a conclusion. Your compliance officer, who often wears several hats, doesn’t get a list of possible hits to sort out.
- Dated records for every person, every month, ready when an auditor, a state Medicaid agency, or OIG asks for your screening history, including for staff who have left.
Plans start at $30 a month for up to 100 people. If your state primary care association has a partnership with us, member pricing may apply; see our program for primary care associations. See pricing or schedule a demo.
What the rules require of health centers
OIG’s Civil Monetary Penalties Law. A health center that submits claims for items or services furnished by an excluded person is liable if it “knew or should have known” the person was excluded. Not knowing is no defense, because a screen would have shown it. “Furnished” covers administrative and support work as well as patient care. A billing clerk or an eligibility specialist whose work supports your claims belongs on the screening roster.
Encounter billing doesn’t dilute the risk. FQHCs are generally paid a per-visit rate for Medicare and Medicaid encounters. If an excluded clinician furnished the visit, the whole encounter payment is at stake.
State lists matter where you bill Medicaid. Screen the Medicaid list of your own state and of any state where your staff live or are licensed. Health centers and tribal programs near a state line, or with service areas that cross one, need each of those lists. See why you should screen every state list.
What it costs when screening fails
Our Beyond the Checkbox analysis doesn’t report health centers as a separate sector, and few OIG settlements since 2020 name a health center. Two that do:
| Year | Health center | Excluded person’s role | Paid |
|---|---|---|---|
| 2020 | MHC Healthcare d/b/a Marana Health Center (Arizona) | Not stated (self-disclosed) | $47,611 |
| 2020 | Morehouse Community Medical Centers (Louisiana) | Not stated (self-disclosed) | $102,245 |
Sources: OIG enforcement actions (Marana Health Center, Morehouse Community Medical Centers).
The bill has two parts. The civil money penalty can reach $24,947 per claim in 2026. On top of that, every claim tied to the excluded person’s work is an overpayment that must be repaid. For staff who don’t bill directly, OIG’s self-disclosure proxy multiplies salary and benefits by your federal payer mix. A health center with a high share of Medicare and Medicaid patients will see that number climb quickly.
Both health centers in the table self-disclosed. Under OIG’s Self-Disclosure Protocol, settlements generally start at a 1.5x multiplier. When the government finds the problem first, the False Claims Act allows treble damages.
Common health center screening mistakes
- Treating the SAM check as the exclusion check. A SAM search done for grant or procurement purposes misses OIG-only and state-only exclusions. Screen all three sources for everyone.
- Screening licensed clinicians and skipping enabling services staff. Community health workers and enrollment staff support billed services and belong on the roster.
- Leaving contractors and volunteers out. If they don’t go through HR onboarding, they often don’t get screened. Add them to the monthly file by name.
- Screening on the grant or budget cycle. Exclusion lists update monthly. An annual check leaves eleven months uncovered.
A screening program for a health center
- Build your rosters. Include every employee, contractor, locum, volunteer clinician, and board member. Give each site its own roster so it gets its own report. Sites are often audited one at a time.
- Screen before the first shift. Check the OIG list, SAM, and the Medicaid list of every state where the person lives, works, or is licensed.
- Re-screen everyone monthly. Treat monthly as the floor.
- Resolve every match the same week. Confirm identity, document the outcome, and pull the person from billable work if the match is real.
- Keep dated records and a response plan. Store results per person, per month. If you confirm an exclusion, stop billing for that person’s services, call counsel, and evaluate self-disclosure.
More on structure: building a compliance program and who must be screened.
Questions health center compliance teams ask
We check SAM for our federal grant. Isn’t that enough?
No. SAM covers federal debarment and suspension. The OIG list and state Medicaid lists are separate sources with their own entries. A person excluded only by your state’s Medicaid program won’t show up in SAM. Screen all three every month for staff, contractors, and board members.
Do we need to screen our board members?
Yes. Board members and officers are part of your organization’s management. An excluded officer or managing employee can be penalized per day, and OIG can exclude the organization they help run. A monthly screen of your board takes little effort.
Do tribal health programs follow the same exclusion rules?
If your program bills Medicare or Medicaid, the same federal and state exclusion lists and the same “knew or should have known” standard apply, and those programs won’t pay for services an excluded person furnished. Programs whose service area crosses state lines should screen each state’s Medicaid list. We screen for tribal nations and Indian health boards today.
Our behavioral health department hires peers in recovery. Anything different there?
Peer specialists and counselors with past convictions need careful screening, because some convictions lead to mandatory exclusion. Our behavioral health page covers that in detail. County-run clinics have their own considerations, covered on our government page.
See SAFER Plus screen a health center roster: clinicians, enabling services staff, contractors, and board members, with matches resolved by our specialists. Schedule a demo →