Exclusion screening for skilled nursing, long-term care, and senior living

Why nursing and senior care facilities are exposed

• Penalties are rising fast. Our Beyond the Checkbox analysis found that senior care moved from the second most-penalized sector to the first in 2025, with $4.5 million across 15 fines.
• One failure can spread across a portfolio. In May 2025, 19 skilled nursing facilities under common ownership paid $1,565,374 in one OIG settlement. Beyond the Checkbox ties this to private equity consolidation in senior care: shared back-office services cut costs, and a shared screening gap spreads the same way. Its 2025 data includes group settlements covering 3 to 19 facilities.
• Your facilities bill Medicare and Medicaid every day. When a long-stay resident’s care is paid by Medicaid, a nurse or aide excluded by that state’s Medicaid program creates liability even if the person is clear on the federal list.
• Nursing staff turn over and float. Nurses and CNAs move between buildings, pick up shifts through staffing agencies, and come back after time away. Each move is a chance to skip the check.

Who to screen

• RNs, LPNs, charge nurses, and directors of nursing
• Certified nursing assistants, medication aides, and resident care aides
• Therapists and rehab staff, whether employed or contracted
• Admissions, social services, activities, dietary, housekeeping, and maintenance staff
• Agency nurses and aides, plus contracted medical directors and consultant pharmacists
• Administrators, regional and corporate staff, owners, and managing employees

The group facilities forget most often is admissions and other non-clinical staff. In 2020 a San Antonio skilled nursing facility paid $143,631 because its excluded employee was the admission director. OIG counts administrative work behind a claim the same as hands-on care.

“We value your partnership and appreciate the excellent customer service you provide.”

Valerie Schul, American Health Management, Inc.

About 1,000 healthcare organizations trust us with their screening every month, including many skilled nursing, long-term care, and senior living organizations. Exclusion Screening was founded by former federal prosecutors Paul Weidenfeld and Robert Liles.

How we handle nursing facility screening

• Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, across every building you operate, with a separate report for each building.
• Identity verification before anything is flagged. CNA and dietary rosters run long and include many common 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 administrators don’t sort through possible hits building by building.
• Dated records for every person, every month, ready for a surveyor, auditor, or acquirer’s diligence team, including for staff who have left or moved to another facility.

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 nursing and senior care facilities

OIG’s Civil Monetary Penalties Law. A facility 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” includes administrative and support work, whether billed separately or bundled into a per diem rate. That covers your admission director and your dietary aides as well as your nurses.

Ownership counts too. OIG can penalize an excluded person who owns or controls a provider up to $24,947 per day, and it can exclude the provider itself. In a market with frequent acquisitions and management company changes, owners and managing employees belong on the roster.

OIG’s nursing facility guidance. In November 2024, OIG published its Industry Segment-Specific Compliance Program Guidance for Skilled Nursing Facilities and Nursing Facilities. It says facilities should check OIG’s exclusion list when screening prospective employees and contractors, and it recommends monthly screening of employees. The guidance is voluntary. Our article on OIG exclusion cases that target nursing homes covers the enforcement history.

Senior living without Medicare or Medicaid billing. An assisted living or independent living community that takes only private pay submits no federal claims, so its CMP exposure is lower. A community that bills a Medicaid waiver program for assisted living services, or shares staff with a skilled nursing building, brings the rules back in. OIG has also excluded an assisted living facility itself: Whispering Knoll in Pine Bluff, Arkansas was excluded in 2020 for defaulting on its exclusion settlement payments (OIG notice).

If your organization also runs a hospice or home health line, those services have their own rules. See exclusion screening for hospice providers and for home health agencies.

What it costs when screening fails

Facility-based senior care paid $9,042,602 in exclusion-related penalties from 2020 through 2025, 29.9% of the $30.2 million total across all sectors, second only to hospitals, according to Beyond the Checkbox.

Recent OIG settlements with skilled nursing and senior care facilities:

Year	Facility	Excluded person’s role	Paid
2025	19 skilled nursing facilities in one settlement, including Sundance Creek Post Acute and Balboa Nursing & Rehabilitation Center	Not stated (multiple individuals)	$1,565,374
2025	Woodlands Senior Living of Cape Elizabeth (Maine)	Not stated	$270,156
2025	Walnut Creek Nursing Center (Ohio)	Licensed practical nurse	$243,001
2024	Tuscany Village Nursing Center (Oklahoma)	Not stated (self-disclosed)	$130,792
2023	Deanwood Rehabilitation and Wellness Center (Maryland)	Licensed practical nurse	$169,683
2020	Meridian Care Monte Vista (Texas)	Admission director	$143,631

Sources: OIG enforcement actions (19 facilities, Woodlands, Walnut Creek, Tuscany Village, Deanwood, Meridian Care). OIG’s legal names: Walnut Creek SNF Opco, LLC; PF Tuscany SNF Ops, LLC; Grant Park SNF LLC; RJ Meridian Care Alta Vista, LLC.

The Maine case matters if you run a small or rural facility. Beyond the Checkbox found six-figure penalties in smaller markets in 2025, Maine among them, and warns that a $300,000 penalty can be devastating for a skilled nursing facility.

The bill has two parts. The civil money penalty can reach $24,947 per claim in 2026. Every claim tied to the excluded person’s work is also an overpayment you must repay. Because a resident’s care is billed daily, one excluded nurse on a unit for a year sits behind a very large number of resident days.

How the problem surfaces changes the math. Under OIG’s Self-Disclosure Protocol, settlements generally start at a 1.5x multiplier on the overpayment, and 57.9% of 2025 resolutions across sectors were self-disclosures. If the government finds it first, the False Claims Act allows treble damages.

Common nursing facility screening mistakes

1. Screening at the building level with different tools. When each administrator runs checks their own way, one building’s gap becomes the whole company’s settlement. The 19-facility case is the example.
2. Checking only the federal lists. If you bill Medicaid for long-stay residents, a nurse excluded by one state’s Medicaid program creates liability even if the federal list is clear. See why to screen every state list.
3. Missing state lists after an acquisition. A corporate office that screens federal lists well can still miss the state list where a newly acquired facility operates. Beyond the Checkbox calls this the “state-line” trap.
4. Trusting agency attestations. Agency nurses and CNAs fill shifts every week. “The agency screens them” is not a dated record in your files. Read why your staffing agency’s screening is not your defense.
5. Leaving non-nursing departments off. Admissions, dietary, housekeeping, and maintenance staff support the care you bill for.

A screening program for a nursing or senior care operator

1. Build a roster for each building. Include agency staff, contractors, consultants, and owners, and keep corporate staff on a roster of their own. Each building gets its own report, which is what a surveyor reviewing that building will ask for.
2. Screen before the first shift. Check federal lists and every state Medicaid list, and don’t put anyone on the schedule until the result is clean.
3. Re-screen everyone monthly. Include PRN and float staff who may not have worked recently.
4. Screen at acquisition. Run the acquired facility’s full roster, against every state list, before closing or on day one.
5. Resolve matches the same week. Confirm identity, document the outcome, and take the person off resident care if the match is real.
6. Keep dated records by facility. Store results per person, per month, so each administrator can answer a surveyor and corporate can answer an acquirer.

More on structure: building a compliance program and screening contractors and vendors.

Questions nursing facility compliance teams ask

We operate several facilities. Is the risk really shared?
It can be. In May 2025, 19 skilled nursing facilities under common ownership settled together for $1,565,374, and Beyond the Checkbox found other 2025 senior care settlements covering groups of facilities. When buildings share HR, staffing pools, and management, a screening gap at one building is likely to exist at the others. One centralized monthly screen closes it everywhere at once.

Do we have to screen agency nurses and CNAs?
Yes. Contracting with a staffing agency doesn’t transfer liability, and the penalty falls on the facility that billed. Ask the agency for dated, per-person screening results, or add agency staff to your own monthly screen. Agency staff who work at more than one of your buildings should be on the central roster.

Does an assisted living community need exclusion screening?
If it bills Medicaid for assisted living services or shares staff with a skilled nursing facility, yes. A purely private-pay community has lower CMP exposure, but referral partners and state rules may still expect it. OIG has excluded an Arkansas assisted living facility after it defaulted on an exclusion settlement, which shows the facility itself can end up off the program.

How often should a facility screen?
Monthly, plus before anyone’s first shift. Exclusion lists update monthly, and the “should have known” standard counts a check you could have run against you.

What should we do when we buy a facility?
Screen the full roster against federal lists and every state Medicaid list before or at closing, and keep the results. The seller may have missed state lists, and an excluded employee who stays on after closing becomes your problem with your first claim.

What do we do if we find an excluded nurse or aide?
Take the person off resident care right away, stop billing for their services, and talk to counsel about OIG’s Self-Disclosure Protocol. Under the protocol, settlements generally start at a 1.5x multiplier on the overpayment, compared with up to treble damages under the False Claims Act if the government finds it first.

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See SAFER Plus screen a multi-facility roster: every building, every state list, matches resolved by our specialists. Schedule a demo →