The disclosure questions: answer precisely, never creatively

What the sanctions questions actually cover

CAQH's sanctions and disciplinary section asks about a distinct category from malpractice claims: state license board actions, hospital or facility privilege restrictions or suspensions, criminal convictions, and any exclusion from a federal or state health program. Each is a separate question with its own scope, and the categories don't substitute for each other — a clean malpractice history says nothing about whether a board action needs disclosing.

Credentialing reviewers treat a board reprimand, a hospital's summary suspension even if brief, or a conditional or probationary license status all as reportable — the norm is to disclose any formal action a licensing or privileging body took, not just the ones severe enough to end a career. A restriction that's since been lifted is still an action that occurred, the same principle that governs how malpractice history gets handled.

Solo clinicians just building caqh proview from zero often assume this section only applies to something dramatic. It applies to anything that fits the categories as written, including administrative actions that felt minor at the time.

Answer the exact question asked — precision over narrative

Read each sanctions question literally before answering it, and answer only what it asks — a question about license restrictions doesn't require volunteering an unrelated hospital privilege matter, and a question about criminal history doesn't require re-litigating a dismissed case in the narrative field. Precision protects you; creative interpretation of the question's scope, in either direction, does not.

That cuts both ways. Answering "no" to a question that technically applies to your situation because you've decided the incident "doesn't really count" is the version that creates real exposure. Answering with more narrative than the question asked for, hoping context will pre-empt scrutiny, tends to introduce new details a reviewer has to now separately verify or question.

If a question's wording is genuinely ambiguous as applied to your specific situation, disclose and explain briefly rather than guessing toward "no" — an over-disclosure that turns out to be unnecessary is a non-event; an under-disclosure that turns out to be required is not. Attestation integrity is exactly this: your certification has to match what independent verification finds, not just what feels defensible when you're filling out the form.

The exclusion screens sit behind the same questions

The sanctions section's questions about federal program exclusion aren't rhetorical — the same information is independently checked against the HHS Office of Inspector General's exclusions database 1Ref 1HHS Office of Inspector General (2026).Exclusions Program.That OIG excludes individuals from federal health programs, that no federal payment may be made for an excluded person's services, and that the LEIE is the public check. and the General Services Administration's SAM.gov records 2Ref 2U.S. General Services Administration (2026).SAM.gov.That SAM.gov is the second federal exclusion/debarment database checked alongside the OIG LEIE., regardless of how you answer. Screening yourself against both before you apply catches a problem on your own terms, before a reviewer finds a mismatch first.

No federal health program payment can be made for services furnished by an excluded individual or entity 1Ref 1HHS Office of Inspector General (2026).Exclusions Program.That OIG excludes individuals from federal health programs, that no federal payment may be made for an excluded person's services, and that the LEIE is the public check., which is why this particular question carries more direct financial consequence than most others on the form — an inaccurate answer isn't just a credentialing problem, it's the kind of thing that surfaces in an audit long after the application was approved.

The practical sequence: check the OIG's exclusions list and SAM.gov yourself before submitting, note the result, and answer from what you actually found rather than from memory or assumption.

Why "no" has to mean permanently, verifiably no

The National Practitioner Data Bank independently collects adverse licensure and privilege actions and reports them to hospitals and health plans that query it directly during credentialing 3Ref 3Health Resources and Services Administration (2026).National Practitioner Data Bank.That the NPDB independently collects adverse licensure and privilege actions and that hospitals and plans query it directly during credentialing, with no public individual lookup.. An inaccurate "no" on a sanctions question isn't a private guess that stays private — it's a claim tested against a federal database that isn't a casual public lookup, but that hospitals and plans query as a routine part of the process 3Ref 3Health Resources and Services Administration (2026).National Practitioner Data Bank.That the NPDB independently collects adverse licensure and privilege actions and that hospitals and plans query it directly during credentialing, with no public individual lookup..

That asymmetry is exactly why a self-query is worth running before you attest 4Ref 4Health Resources and Services Administration (2026).NPDB Self-Query.That a practitioner can self-query the NPDB and see exactly what a credentialing committee's query will surface before answering a sanctions question.: it shows you precisely what a credentialing committee's NPDB query will surface, which lets you answer the sanctions question accurately from the actual record rather than from your memory of events that may be years old.

A "no" that later turns out to be wrong reads as a credibility failure regardless of intent — reviewers generally can't distinguish an honest oversight from a deliberate omission from the outside, so the safer posture is checking first rather than answering from confidence.

If you discover an unreported issue after attesting

If you realize after attesting that a sanctions answer was inaccurate — a board action you'd genuinely forgotten, or one you now understand should have been disclosed — correct it directly in your CAQH profile as soon as you notice, rather than waiting for your next scheduled attestation to quietly fix it. A prompt, voluntary correction reads very differently to a reviewer than the same fact surfacing through someone else's query.

For something with genuine fraud or program-integrity implications, beyond a simple missed disclosure, OIG maintains a formal self-disclosure protocol for providers who identify conduct implicating federal health program rules 5Ref 5HHS Office of Inspector General (2026).Health Care Fraud Self-Disclosure Protocol.That OIG maintains a formal self-disclosure protocol for providers who identify conduct implicating federal health program fraud rules, a more serious track than correcting a CAQH answer.. That's a different and more serious track than correcting a CAQH answer, reserved for matters your own judgment — or your attorney's — flags as beyond a paperwork fix; most missed sanctions disclosures don't rise to that level and are resolved by simply correcting the profile.

Consistency with your board file and every other form

Your state license board, any hospital where you hold or held privileges, and every payer you're contracted with may separately ask a version of this same question, and a credentialing reviewer who finds two different accounts of one action treats the discrepancy as the issue, not the action itself. Keep one internal record of exactly what happened and how you've disclosed it everywhere, and copy from that record every time.

This matters most at two recurring moments: hospital reappointment, which typically runs on its own cycle independent of your CAQH attestation, and recredentialing every three years or so under NCQA's standard cycle, when a payer re-runs the same questions against whatever's changed since your last attestation. Board certification renewals and other credentialing-standards touchpoints ask versions of the same question too — treat every one of them as reading from the same single record, not as an opportunity to phrase things differently.