The OIG’s guidance is clear and the case law is consistent: any person or entity whose salary, fees, or compensation is paid for in whole or in part by Medicare, Medicaid, or another federal healthcare program must be screened against the LEIE before hire or engagement — and monthly thereafter. That rule reaches further than most compliance programs assume. It covers employees, but also board members, volunteers, contracted nurses, locum physicians, IT vendors, billing companies, medical directors, transportation providers, janitorial services billed to federal funds, and anyone else whose work touches the patient, the claim, or the revenue stream.
What this guide will cover
- The “indirect reimbursement” rule and why it pulls vendors into scope
- Covered persons vs. covered entities under 42 CFR 1001
- Board members, volunteers, and contracted professionals — when they’re in scope
- Vendor screening obligations (the piece most compliance programs get wrong)
- Subcontractor chains — how deep the screening obligation runs
- Pre-hire vs. ongoing screening frequency
- Special categories: telehealth providers, staffing agencies, locum physicians
Read now
- The Definitive Guide to OIG Exclusions — Section 3 covers the covered-persons rule in depth.
- Exclusion Screening — how our platform handles employee and vendor screening in one workflow.
- The Legal Guide to OIG Exclusions — the regulatory basis for screening obligations.
- Free Compliance Assessment — 10-question diagnostic that surfaces common coverage gaps.
- Contractor & Vendor Screening — vendor-specific workflow.
Talk to our team
Most compliance programs screen employees well and vendors poorly. If you’re not sure where your coverage ends, that’s the gap worth closing first.