Exclusion screening for government agencies and public institutions

Why public entities are exposed

• Medicaid billing reaches well past the health department. Human services, public health clinics, hospital districts, EMS, and school-based services can all bill Medicaid. School districts, for example, often bill Medicaid for services such as speech therapy and nursing for students with disabilities. Every department that bills needs its staff screened.
• The government itself pays the penalty. The settling party in recent cases was “the State of Mississippi” for its university medical center and “the State of Montana” for its state hospital. The money comes out of a public budget.
• Central administration is a target. Our Beyond the Checkbox report notes that university administration offices are less obvious targets than academic medical centers. Two university regents offices have self-disclosed in recent years, with penalties around $150,000 each.
• Vendors and contractors are part of the obligation. Counties often need to check vendors and contractors as well as employees. When federal award money pays for a contract of $25,000 or more, federal rules require you to confirm the contractor isn’t suspended or debarred before you sign.

Who to screen

• Public health nurses, clinic staff, and immunization and family planning staff
• Human services case managers and county behavioral health staff
• Hospital district and county hospital employees
• School nurses, speech-language pathologists, occupational and physical therapists, school psychologists, and aides who deliver billed services
• EMS crews and dispatchers in county or district services
• University clinical faculty, researchers who see patients, and administrative staff in central offices
• Contractors, temporary staff, and vendors paid with health program funds
• Elected or appointed board members of health districts and hospital districts, and department heads

The group public entities forget most often is central administrative staff. A university or county may screen clinic employees and leave out the central offices that manage billing, payroll, and contracts for them. Beyond the Checkbox flags university regents offices as exactly this blind spot.

“It does GSA screening which is otherwise difficult… The completed analysis that is sent back has been timely. Pricing seems reasonable given the amount of time it saves compared to doing GSA checks ourselves.”

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 counties, public health departments, and public hospitals. Exclusion Screening was founded by former federal prosecutors Paul Weidenfeld and Robert Liles.

How we handle screening for public entities

• Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, across every department that bills, plus the vendors and contractors your procurement office manages.
• Identity verification before anything is flagged. A county or university roster can run into thousands of names, so we confirm identity with Social Security number, date of birth, NPI, or license data before calling something a match.
• Our specialists resolve matches. When a name comes back, one of our trained specialists works it to a conclusion. Your HR or compliance office doesn’t get a list of possible hits to clear on its own.
• Dated records for every person, every month, ready when a state auditor, a federal grant reviewer, or OIG asks for your screening history, including for employees who have left.

Plans start at $30 a month for up to 100 people, with custom pricing for larger rosters. See pricing or schedule a demo.

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What the rules require of public entities

OIG’s Civil Monetary Penalties Law. An organization 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. Public status is no defense. The settlements below were paid by states, a county department, a health district, and university boards of regents. “Furnished” covers administrative and support work as well as patient care, so a billing clerk in a county finance office can create exposure.

State Medicaid lists apply on their own. A person can be excluded by a state Medicaid program without appearing on the federal OIG list. In 2025 Chicago’s John H. Stroger, Jr. Hospital of Cook County paid $456,401 for two employees excluded only by Illinois Medicaid. See why you should screen every state list.

Vendor and contractor screening. Agencies that spend federal award money must confirm that contractors on covered contracts (generally $25,000 or more) are not suspended or debarred. The rule lets you check SAM, collect a certification, or add a contract clause. Checking SAM is the only one of the three that tells you what’s actually on the list. Our article on contractor and vendor screening explains which lists apply, and our SAM explainer covers how that database works.

What it costs when screening fails

Education and government entities paid $859,068 in exclusion-related penalties from 2020 through 2025, 2.8% of the $30.2 million total across all sectors, according to our Beyond the Checkbox analysis.

Recent OIG settlements with public entities:

Year	Entity	Excluded person’s role	Paid
2025	The State of Mississippi, University of Mississippi Medical Center (Mississippi)	Not stated	$368,043
2023	Regents of the University of California, on behalf of UCLA Health (California)	Not stated	$136,498
2022	The State of Montana d/b/a Montana State Hospital (Montana)	Not stated	$89,233
2022	Harney County Health District (Oregon)	Not stated	$10,000
2021	Regents of the University of Minnesota (Minnesota)	Not stated	$150,778
2020	Green County Human Services (Wisconsin)	Not stated	$128,798

Sources: OIG enforcement actions (University of Mississippi Medical Center, UCLA Health, Montana State Hospital, Harney County Health District, University of Minnesota, Green County). Also cited above: Stroger Hospital of Cook County. Other public bodies that settled include the University of Virginia’s Rector and Visitors ($66,858, 2024) and St. Tammany Parish Hospital Service District No. 2 in Louisiana ($20,000, 2024).

Every entity in the table self-disclosed, and each case involved a single excluded employee. Harney County’s $10,000 shows the low end. The State of Mississippi’s $368,043 shows how far one person can push it.

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 $100,000 employee at 50% federal payer mix produces a $50,000 overpayment for each year worked.

Under OIG’s Self-Disclosure Protocol, settlements generally start at a 1.5x multiplier. When the government or a whistleblower finds the problem first, the False Claims Act allows treble damages.

Common screening mistakes at public entities

1. Screening the health department and stopping there. Any department whose staff support Medicaid or Medicare claims needs screening, including school special education programs, human services, and central billing.
2. Relying on a civil service background check. A criminal history check doesn’t tell you whether OIG or a state Medicaid program has excluded someone. Run both.
3. Checking vendors against SAM only. SAM covers debarment. The OIG list and state Medicaid lists are separate sources, and a contractor who furnishes billed services needs all of them checked.
4. Assuming public status means lighter enforcement. States, counties, and boards of regents have all paid. OIG applies the same “knew or should have known” standard.
5. Screening on the fiscal-year cycle. Lists update monthly. An annual check tied to budget season leaves eleven months uncovered.

A screening program for a public entity

1. Map every department that bills. List each program that submits Medicare or Medicaid claims, directly or through a billing agent, and the staff who support it.
2. Build your rosters. Include employees, temporary and contract staff, vendors paid with health program funds, and board members. Give each department or clinic its own roster so it gets its own report. Departments are often audited one at a time.
3. Screen before the first day. Check the OIG list, SAM, and the Medicaid list of every state where the person lives, works, or is licensed.
4. Re-screen everyone monthly. Treat monthly as the floor, including vendors.
5. Resolve every match the same week. Confirm identity, document the outcome, and pull the person from billable work if the match is real.
6. 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 public-sector compliance teams ask

Does the penalty law really apply to a state or county?
Yes. OIG has settled with the State of Mississippi, the State of Montana, the Regents of the University of California and of the University of Minnesota, Green County Human Services in Wisconsin, and Harney County Health District in Oregon. Each self-disclosed one excluded employee. If your entity bills federal health care programs, the “knew or should have known” standard applies.

Our school district bills Medicaid for special education services. Who do we screen?
Everyone who furnishes or supports the billed services: speech-language pathologists, therapists, school nurses, psychologists, and the aides and billing staff behind them. Contracted therapists count too. A district that bills through a third-party billing company still owns the claims.

Do we have to screen our vendors?
If they furnish items or services tied to Medicare or Medicaid claims, yes. Spending federal award money adds a separate requirement: for covered contracts, you must confirm the vendor isn’t suspended or debarred, and a SAM check is the most direct way to do it. A single monthly screen against SAM, the OIG list, and the state Medicaid lists covers both.

We’re a university. Does this reach beyond the medical center?
It can. Beyond the Checkbox notes that academic medical centers face the same penalties as other hospitals, and that university administration offices are a less obvious target. Two university regents offices self-disclosed in recent years, with penalties around $150,000 each.

What about our county hospital or hospital district?
Public hospitals carry the same exposure as private ones, plus the budget constraints of a public body. Stroger Hospital of Cook County and St. Tammany Parish Hospital Service District No. 2 both settled recently. Our hospitals page covers hospital screening in detail, and county clinics that operate as health centers can see our community health centers page.

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See SAFER Plus screen a public-sector roster: every department that bills, plus the contractors and vendors behind it, with matches resolved by our specialists. Schedule a demo →