Exclusion screening for clinical laboratories

Why laboratories are exposed

• One person sits behind thousands of claims. A lab bills per test. An excluded accessioner, tech, or courier who handles specimens every shift touches a large volume of claims, and every one of them is an overpayment that has to be repaid.
• Texas enforcement has gone after labs. Our Beyond the Checkbox analysis found that Texas settlements centered on ancillary providers such as labs and ambulance services. The biggest lab case in the period, Clinical Pathology Laboratories in Austin, accounts for about three-quarters of the sector’s total.
• You bill on orders from clinicians you don’t employ. Medicare and Medicaid won’t pay for a test ordered by an excluded physician when you knew or should have known of the exclusion, and any payment you received is an overpayment you owe back. OIG expects you to check the ordering physician. A test ordered by an excluded physician can be a problem claim even when everyone on your payroll is clean.
• Your client base crosses state lines. A lab that receives specimens from several states and bills those Medicaid programs is exposed to each state’s exclusion list, and 43 states plus DC keep their own (46 lists in all).

Who to screen

• Medical technologists, lab techs, and specimen processors, including night-shift and per diem staff
• Phlebotomists at patient service centers, nursing home draws, and in-office placements
• Couriers and drivers, whether employed or supplied by a logistics vendor
• Pathologists and reading radiologists, including contracted and teleradiology readers
• Sales reps, client services, and billing staff
• Owners, lab directors, and managing employees
• Ordering physicians and other practitioners in your client file

The group labs forget most often is couriers. They often come through a delivery vendor and don’t feel like healthcare staff, so they never reach the HR screening queue. Their work still sits behind every specimen you bill, and “furnished” covers support work as well as clinical work. Lab techs show up in enforcement outside reference labs too: in 2024 a New Jersey physician group paid $25,810 because its excluded employee was a lab technician and supervisor.

“I cannot tell you enough how much I appreciate all your help with the service, for getting the reports out this month…”

Nancy Ware, CHC, Senior HIPAA Compliance Specialist, Total Medical Compliance

About 1,000 healthcare organizations trust us with their screening every month, including many laboratories and imaging centers. Exclusion Screening was founded by former federal prosecutors Paul Weidenfeld and Robert Liles.

How we handle laboratory screening

• Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, including the states your client accounts send specimens from.
• Identity verification before anything is flagged. We confirm identity with Social Security number, date of birth, NPI, or license data, so a courier or phlebotomist with a common name doesn’t stall your onboarding.
• Our specialists resolve matches. When a name comes back, one of our trained specialists works it to a conclusion, whether it’s a tech on your payroll or a pathologist in a contracted reading group.
• Dated records for every person, every month, ready when a payer audit or OIG inquiry asks for your screening history, including for staff and vendor couriers who have left.

Plans start at $30 a month for up to 100 people. See pricing or schedule a demo.

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What the rules require of laboratories

OIG’s Civil Monetary Penalties Law. A lab 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 not a defense, because a screen would have shown it. “Furnished” includes administrative, support, and clinical work, whether it’s billed separately or bundled. A courier or specimen processor never appears on a claim form, and their work still counts.

Ordering and prescribing. Beyond the Checkbox lists ordering or prescribing while excluded as a penalty basis under 42 C.F.R. §1003.200(b)(6). That penalty falls on the excluded physician who orders, not on the lab. The lab’s risk is that the program won’t pay for the test, and any payment is an overpayment you owe back. OIG’s 2013 Special Advisory Bulletin also warns that labs relying on someone else’s check may be responsible for overpayments and civil money penalties. OIG has pursued claims tied to excluded orderers: in a 2022 Ohio settlement, it alleged that Summa Health billed Medicaid or paid claims for services or durable medical equipment ordered by three excluded physicians who were not on Summa’s medical staff (OIG). For a lab, the ordering-provider file belongs in the screening program.

State Medicaid lists. A person can be excluded by a state Medicaid program without appearing on the federal OIG list. If you bill Medicaid in a state, that state’s list applies. See why we screen every state exclusion list.

None of this moves to a vendor. If a staffing firm or courier company screens its own people and misses one, the penalty still lands on the lab that billed (why your staffing agency’s screening is not your defense).

What it costs when screening fails

Laboratories paid $471,332 in exclusion-related penalties from 2020 through 2025, 1.6% of the $30.2 million total across all sectors, according to our Beyond the Checkbox analysis. The three self-disclosed settlements below make up that entire figure.

Year	Laboratory	Excluded person’s role	Paid
2025	Clinical Pathology Laboratories (Texas)	Not stated (self-disclosed)	$352,624
2025	Exact Sciences Laboratories (Wisconsin)	Not stated (self-disclosed)	$85,139
2025	Advanced Clinical Laboratory (Louisiana)	Not stated (self-disclosed)	$33,569

Sources: OIG enforcement actions (Clinical Pathology Laboratories, Exact Sciences, Advanced Clinical Laboratory).

All three landed in 2025, and all three labs reported the problem themselves. That timing is a good reason to look back through your own roster history now.

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. For staff who don’t bill directly, such as couriers or processors, OIG uses a proxy under self-disclosure: salary and benefits multiplied by your federal payer mix. A $100,000 employee at a 50% federal mix means a $50,000 overpayment before any penalty.

Under OIG’s Self-Disclosure Protocol, settlements generally start at a 1.5x multiplier. If the government or a whistleblower finds it first, the False Claims Act allows treble damages, and OIG is no longer bound by the salary proxy.

Common laboratory screening mistakes

1. Screening employees and ignoring the ordering-provider file. Your own staff can all be clean while tests from an excluded physician flow into your billing system.
2. Leaving vendor couriers and contract phlebotomists off the roster. A logistics company’s assurance that it screens its drivers gives you no dated record to show OIG.
3. Treating the reading group as someone else’s problem. Contracted pathologists and teleradiology readers furnish the interpretation you bill. Screen each reader by name and NPI, monthly.
4. Checking pathologists only at credentialing. A two-year recredentialing cycle leaves 23 months uncovered. Exclusion lists update monthly.
5. Federal lists only. If your clients send specimens from several states, every state Medicaid program you bill brings its own list.

A screening program for a laboratory

1. Build your rosters. Include employees, per diem staff, contract phlebotomists, vendor couriers, contracted pathologists and radiologists, and owners and managing employees. Give each lab or patient service center its own roster so it gets its own report. Sites are often audited one at a time.
2. Add your ordering-provider file. Screen the clinicians who order tests from you, matched by NPI. Our guide to screening the NPPES registry explains why the NPI matters.
3. Screen before the first shift or first read. Check federal lists and the Medicaid list of every state you bill.
4. Re-screen everyone monthly. Treat monthly as the floor; see why monthly screening.
5. Resolve every match the same week. Confirm identity, document the outcome, and pull the person from billable work if it’s real.
6. Have a response plan. If you confirm an exclusion, stop billing for that person’s work, call counsel, and evaluate self-disclosure. Here’s what to do with a confirmed exclusion.

Questions laboratory compliance teams ask

Do we have to screen couriers who never touch a patient?
Yes. OIG’s definition of “furnished” covers support and administrative work that sits behind a claim, and a courier moves the specimen you bill for. If a delivery vendor supplies your drivers, get their names and screen them monthly yourself, or require dated per-person results. Delegating the screening doesn’t move the penalty off your lab.

Should we screen the physicians who order tests from us?
We recommend it. OIG says labs should confirm at the point of service that the ordering physician is not excluded, and it has pursued organizations for billing or paying for services ordered by excluded physicians who weren’t on staff. Screening your client file by NPI each month catches an excluded orderer before months of their tests reach your claims.

Our pathologists are credentialed by the hospital we serve. Is that enough?
No. Hospital credentialing runs on its own schedule and is built to protect the hospital’s claims. If your lab bills for the professional or technical component, you need your own dated monthly records for each pathologist.

Does this apply to diagnostic imaging centers?
Yes, the same rules apply to any organization billing federal programs. For an imaging center, the reading radiologist is the highest-value person to screen, especially contracted and teleradiology readers who never set foot in your building. Technologists, schedulers, and front-desk staff belong on the roster too. Labs that also supply equipment or orthotics should see exclusion screening for DME suppliers.

We found an excluded tech. What happens next?
Remove the person from billable work, stop billing for their services, and talk to counsel about self-disclosure. All three lab settlements from 2020 through 2025 came through self-disclosure, where settlements generally start at a 1.5x multiplier, compared with up to treble damages under the False Claims Act.

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See SAFER Plus screen a lab roster: techs, couriers, contracted readers, every state list, matches resolved by our specialists. Schedule a demo →