Exclusion screening for healthcare staffing agencies

When an excluded nurse you placed turns up at a client, the client pays the penalty, and then it reconsiders how much it uses agencies. One West Coast health system had six exclusion incidents across its locations while it leaned on staffing agencies from 2020 to 2024, self-disclosed more than $1 million in penalties, and cut its use of agency nurses by 43%. We screen your whole clinician pool every month and gives you dated records you can hand to every client.

Schedule a demo

See pricing

Why staffing agencies are exposed

Your clients carry the penalty and remember who sent the worker. Delegating screening to an agency doesn’t move the provider’s liability, so the client pays. After the West Coast system’s incidents, the response was fewer agency nurses.
The penalty lands on your client, and the cost comes back to you. OIG’s penalties fall on the hiring organization because they are the entity billing the government health programs. Your exposure arrives through your client contract.
Your workers cross state lines. Travel and per diem clinicians work in states where you may never have checked the Medicaid exclusion list. Penalties for missed state-only exclusions grew from about $20,000–$60,000 in 2020 to $450,000–$860,000 in recent cases.
OIG settlements already describe contractor placements. In three 2020–2025 settlements, OIG said the provider employed an excluded person “through a contractor.”

Who to screen

RNs, LPNs, and CNAs, including travel, per diem, and local contract staff
Allied health and medical technicians
Therapists: physical, occupational, speech, and respiratory
Workers you place through sub-vendors or other agencies under your contract
Recruiters and credentialing staff with access to client systems
Owners, officers, and managing employees of the agency

The group agencies forget most often is the bench: clinicians who were screened at onboarding, went months without an assignment, and are then placed again on the strength of a stale check.

“You guys did a great job! The new system looks great and was easy to navigate and upload!!! The process was a lot quicker so I appreciate all the new features.”
Lisa Robinson, Chief Operating Officer, Healthcare Compliance Network

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

How we handle staffing agency screening

Monthly screening of your whole roster against the OIG LEIE, SAM, and all state Medicaid exclusion lists, covering every clinician in your pool, on assignment or between them.
Identity verification before anything is flagged. We confirm identity with Social Security number, date of birth, NPI, or license data, so a common name never stalls a placement that should go ahead.
Our specialists resolve matches. When a name comes back, one of our trained specialists works it to a conclusion before you decide whether to submit that clinician to a client.
Dated records for every person, every month, that you can send to a client facility as proof that each worker you placed was screened, including workers whose assignments have ended.

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

What the rules require of staffing agencies

The screening rules are written around the provider that bills, which is why clients push the work, and the proof, onto you.

Your clients’ liability. A provider that submits claims for services furnished by an excluded person is liable if it “knew or should have known” the person was excluded. Contracting pre-hire screening out to you doesn’t transfer that liability. We explain the client’s side in why your staffing agency’s screening is not your defense. Clients who have read it will ask you for records.

Your own exposure. The penalty falls on the hiring organization, not the agency, because they are the entity billing the government health programs. Your exposure is your client contract. Look for representations that every worker is screened and for indemnification terms.

Home health clients. The 2017 home health Conditions of Participation require agencies to make sure entities furnishing services under arrangement have not been excluded. If you supply home health agencies, expect them to ask for screening evidence on every aide and nurse. See exclusion screening for home health agencies.

What it costs when screening fails

Beyond the Checkbox doesn’t break out staffing agencies as a sector, and we found no 2020–2025 OIG settlement against a staffing agency or nurse registry. The penalties land on the providers that took the placements. These are the settlements where OIG said the excluded person came through a contractor:

Year	Provider	Excluded person’s role	Paid
2025	Kidspeace National Centers of New England (Maine)	Speech pathologist	$44,737
2024	Mercy Health Youngstown d/b/a St. Elizabeth Boardman Hospital and St. Joseph Warren Hospital (Ohio)	Not stated (self-disclosed)	$69,362
2020	St. Vincent Hospital and MetroWest Medical Center (Massachusetts)	Not stated (self-disclosed)	$41,495

Sources: OIG enforcement actions (Kidspeace, Mercy Health, St. Vincent). OIG doesn’t say what kind of contractor was involved in any of them.

For the client, the CMP can reach $24,947 per claim, and every claim tied to the excluded worker’s services must be repaid. Under OIG’s Self-Disclosure 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. A nurse working full shifts on a unit touches many claims a week. For you, the cost is the contract. The West Coast system’s 43% cut in agency nurses is what a client’s response can look like. More cases are collected in historical OIG settlements and penalties.

Common staffing agency screening mistakes

Screening once at onboarding. A clinician who cleared in January can be excluded by June and still be in your pool.
Re-placing the bench without a fresh check. Run a current screen before anyone returns to an assignment.
Checking only the federal lists for travel staff. Screen the Medicaid list of every state where the clinician works and where your clients bill.
Sending clients an attestation instead of records. A client facing the “should have known” standard needs dated, per-person results it can produce.
Skipping sub-vendor workers. If a clinician is placed under your contract, your client treats them as yours.

A screening program for a staffing agency

Build your rosters. Include every clinician in your pool, active or inactive, plus sub-vendor placements, recruiters, and owners. Give each client, branch, or location its own roster so each one gets its own report. Splitting by client lets you hand every client a report that covers only its placements.
Screen before submission. Check federal lists and the Medicaid list of every state the clinician could work in before you put them forward.
Re-screen the whole pool monthly. Monthly is the floor, whether or not someone is on assignment.
Set a client notification rule. Decide in writing how fast you tell a client about a confirmed match on a placed worker.
Keep dated records per placement. Be able to show which worker was screened, when, for which client, including for ended assignments.
Have a response plan. Pull a confirmed worker from assignment immediately, notify the client, and call counsel.

More on structure: screening contractors and vendors and why monthly screening.

Questions staffing agency compliance teams ask

Our clients screen our nurses themselves. Why should we?
Some do, and some rely on your word. Either way, when an excluded worker you placed shows up, the client pays and you take the blame. Monthly screening on your side catches the problem before submission, and your records let a client confirm screening without redoing it. That makes you an easier vendor to keep.

Can OIG penalize a staffing agency directly?
The penalty falls on the hiring organization, because they are the entity billing the government health programs. In the settlements we’ve reviewed, the penalty landed on the provider. Your contract with that provider is where you’ll feel it first.

What screening proof do clients want?
Dated, per-person results showing each worker was checked against the federal lists and the relevant state Medicaid lists, every month they were placed. A policy or an attestation isn’t the same. Our records show who was screened, which lists, and when, and they cover workers whose assignments have ended.

Which state lists do we need for travel nurses?
At minimum, the Medicaid exclusion list of every state where the nurse works and every state where your client bills Medicaid. A person excluded by one state’s Medicaid program may not appear on the OIG list. We screen all state Medicaid exclusion lists, so you don’t have to track assignments state by state. See why to screen every state list.

What if a worker on assignment comes back excluded?
Pull the worker from the assignment right away and tell the client the same day. The client will need to stop billing for that person’s services and decide with counsel whether to self-disclose. Your dated records show when the worker was last screened clean, which matters to that decision. See what to do with a confirmed exclusion.

If you also place clinicians with health plans, see exclusion screening for health plans.

See SAFER Plus screen a staffing pool: every clinician, every state list, records ready for each client. Schedule a demo →