Guide

Exclusion screening: yourself, your staff, monthly

Summary

Yes — monthly is the recommended cadence because OIG updates the LEIE on that cycle, and a less frequent check leaves a real gap between when someone is added and when you'd catch it. The screening obligation covers you and anyone furnishing services under your NPI — staff, contractors, supervisees billed incident-to. Check both the LEIE and SAM.gov, since the two databases don't fully overlap, and no federal program may pay for services an excluded person furnished, regardless of intent.

By Gale Editorial · Updated 2026-07-26. Every figure cited to a dated source. How we write.

Why 'monthly' is the number that keeps coming up

OIG's exclusion program bars any federal program from paying for items or services furnished by an excluded individual or entity, and the List of Excluded Individuals and Entities is the public record showing who's on that list 1Ref 1HHS Office of Inspector General (2026).Exclusions Program.That OIG excludes individuals/entities from federal health programs, that no federal program payment may be made for items or services furnished by an excluded person, and that the LEIE is the public, regularly-updated check.. OIG maintains and refreshes the LEIE on a recurring monthly cycle, which is the practical reason monthly keeps showing up as the recommended check cadence rather than an arbitrary compliance-calendar habit.

A less frequent check — quarterly, or only at hire — leaves a real gap: someone can be added to the list mid-month, and every claim billed for their services between the addition and your next check is a claim a federal program shouldn't have paid. The monthly cadence exists because that's how often the underlying list itself changes, not because compliance officers picked a round number.

Who actually needs to be screened

The screening obligation doesn't stop at you. Anyone who furnishes a service billed to a federal program under your NPI — an associate, a contractor, front-desk staff handling billing, a supervisee whose work you bill incident-to your own services — needs the same exclusion check, because the payment prohibition attaches to the person who furnished the service, not only to whoever signs the claim.

This is exactly where the incident-to regulation matters: when you bill a supervisee's work incident-to your own services, the requirement runs through a defined supervision and employment relationship 2Ref 2Office of the Federal Register (2026).42 CFR 410.26 — Services and supplies incident to a physician's professional services.The regulation defining incident-to requirements — direct supervision, employment/contract relationship — supporting why a supervisee's exclusion status is the billing clinician's liability., and that same relationship is what makes their exclusion status your liability, not just theirs. Screen every name on your payroll and every contractor who touches a patient encounter, not only the clinicians whose names appear on claims.

SAM.gov: the second database, not a duplicate

SAM.gov is a separate federal exclusion and debarment system, and credentialing-grade screening generally checks both it and the LEIE, since the two databases don't fully overlap 3Ref 3U.S. General Services Administration (2026).SAM.gov.That SAM.gov is the federal exclusion/debarment check complementing the OIG LEIE, supporting the two-database screening convention.. Checking only one and assuming it covers the other is a common shortcut that leaves a gap neither list alone would show you.

Run both checks on the same monthly pass rather than treating SAM.gov as an occasional extra — the incremental effort of checking a second free federal database is small compared to running two separate compliance calendars for what is functionally one monthly task.

What happens if you miss one

If an excluded person furnishes a service that gets billed to a federal program, no payment may be made for it — full stop, regardless of whether anyone involved knew about the exclusion at the time 1Ref 1HHS Office of Inspector General (2026).Exclusions Program.That OIG excludes individuals/entities from federal health programs, that no federal program payment may be made for items or services furnished by an excluded person, and that the LEIE is the public, regularly-updated check.. Discovering this after the fact turns a screening gap into a repayment obligation, and potentially into a disclosure obligation depending on how the payment happened and how long it went uncorrected.

If you discover you've billed for an excluded individual's services, OIG's own self-disclosure protocol is the path for reporting conduct that implicates federal health program fraud law, including this exact scenario 4Ref 4HHS Office of Inspector General (2026).Health Care Fraud Self-Disclosure Protocol.That OIG maintains a self-disclosure protocol for providers who discover conduct implicating federal health program fraud law, supporting the found-a-problem escalation path. — it exists precisely because coming forward proactively is treated very differently than having it found in an audit. A missed monthly check is a fixable gap; an unreported one that surfaces later is a much harder conversation.

Screening a hire vs. the ongoing monthly check

The obligation doesn't stop with screening a hire before their start date — someone clean at hire can be added to the LEIE or SAM.gov at any point afterward, which is exactly why the check has to repeat monthly rather than run once and get filed away. Treat hire-time screening and the ongoing monthly check as two distinct steps, not one event.

The same logic applies to your own name: a self-query of the National Practitioner Data Bank checks a different database for a different thing — malpractice payments and adverse actions rather than program exclusion — but it runs on the same principle of checking yourself on the same cadence a credentialing reviewer would 5Ref 5Health Resources and Services Administration (2026).NPDB Self-Query.That any practitioner can self-query the NPDB and see what a credentialing committee would see, supporting the parallel self-check-on-a-cadence framing.. Neither check substitutes for the other; both are worth running on a schedule you actually keep.

Building it into a monthly habit

The practices that keep this current tend to fold it into a monthly routine they're already running rather than treating it as a separate compliance chore — the same discipline behind the 90-minute monthly close many solo practices use for bookkeeping applies just as well to a five-minute exclusion check on two websites.

A useful compliance touchstone here is the oig's small-practice guidance, which names screening among the handful of elements a basic compliance program needs — a reminder that this doesn't require a formal program to be worth doing consistently — just a recurring line item on whatever monthly review already has your attention, whether that's the solo dashboard or the same sitting where you read the p&l in ten minutes.

Common questions

Monthly is the recommended cadence because that's how often OIG refreshes the LEIE. A quarterly or annual check leaves a real gap — someone can be added mid-cycle, and every claim billed for their services in that gap is a claim a federal program shouldn't have paid.

Both. The payment prohibition attaches to whoever furnished the service, not only to whoever signs the claim. Anyone billing under your NPI — an associate, a contractor, front-desk staff, a supervisee billed incident-to your services — needs the same exclusion check you run on yourself.

No. SAM.gov is a separate federal exclusion and debarment system, and the two databases don't fully overlap. Credentialing-grade screening checks both, and assuming one covers the other is a common shortcut that leaves a real gap neither list alone would show you.

No federal program payment may be made for those services, regardless of whether anyone knew about the exclusion at the time. If you discover this after the fact, OIG's self-disclosure protocol is the path for reporting it — coming forward proactively is treated very differently than having it surface in an audit.

No. Someone clean at hire can be added to the LEIE or SAM.gov at any point afterward, which is why the check has to repeat monthly rather than run once. Treat hire-time screening and the ongoing monthly check as two distinct steps, not a single event.

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References

1.HHS Office of Inspector General (2026). Exclusions Program. HHS Office of Inspector General (OIG). link ✓That OIG excludes individuals/entities from federal health programs, that no federal program payment may be made for items or services furnished by an excluded person, and that the LEIE is the public, regularly-updated check.
2.Office of the Federal Register (2026). 42 CFR 410.26 — Services and supplies incident to a physician's professional services. eCFR. link ✓The regulation defining incident-to requirements — direct supervision, employment/contract relationship — supporting why a supervisee's exclusion status is the billing clinician's liability.
3.U.S. General Services Administration (2026). SAM.gov. U.S. General Services Administration. linkThat SAM.gov is the federal exclusion/debarment check complementing the OIG LEIE, supporting the two-database screening convention.
4.HHS Office of Inspector General (2026). Health Care Fraud Self-Disclosure Protocol. HHS Office of Inspector General (OIG). link ✓That OIG maintains a self-disclosure protocol for providers who discover conduct implicating federal health program fraud law, supporting the found-a-problem escalation path.
5.Health Resources and Services Administration (2026). NPDB Self-Query. U.S. Health Resources and Services Administration (HRSA). link ✓That any practitioner can self-query the NPDB and see what a credentialing committee would see, supporting the parallel self-check-on-a-cadence framing.

https://www.gale.care/for-providers/lm-oig-leie-monthly · 5 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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