EXCLUSION SCREENING
Exclusion screening you can prove you did.
Running the check is the easy half. The half that gets asked about is the one where you show which names were screened, against which list, on what date, and who decided that the match was not your employee.
Screening is only half the obligation. The other half is proving it.
An exclusion check that nobody can reconstruct is, for practical purposes, a check that did not happen. The question in a review is never “do you screen?” — everyone says yes. It is show me the December run: the roster as it stood that month, the list version you screened against, the hits, and what was concluded about each one.
That is a records problem more than a searching problem, and it is where a spreadsheet of names and a folder of PDF printouts stops being defensible. Not because it is wrong, but because reassembling it takes days and the reassembly itself is not evidence.
RIEL keeps the run as the unit. Each screening cycle is a record: who was in scope, which lists were queried, what came back and how each result was dispositioned — with the name of the person who dispositioned it.
OIG LEIE, SAM.gov and the state lists that apply to you.
Three sources, three different failure modes. The federal exclusion list is the one everyone knows; the SAM.gov exclusion records cover a broader set of federal actions; and applicable state lists are the ones most often screened once and then forgotten.
- OIG LEIE
- SAM.gov
- Applicable state screening
- Stored evidence
How often, and who says so.
RIEL does not invent a screening frequency for you, and it does not claim one is required where none is. What it does is make a defined cadence practical to run and, more to the point, practical to evidence a year later.
What the OIG actually says. In its Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (May 2013), the OIG advises providers to screen employees and contractors against the List of Excluded Individuals/Entities, and states that checking the LEIE monthly best minimizes potential overpayment and civil monetary penalty liability. That is guidance on how to limit exposure — read the Bulletin itself for its exact terms rather than a vendor's summary of it.
The LEIE is updated monthly by the OIG, which is where the monthly cadence comes from: screening more often than the list changes adds records, not protection.
Your own obligations may be stricter. State Medicaid agencies, your contracts and your own compliance program can each set a shorter interval or a wider scope than the federal guidance. Those are the terms that bind you, and they are the ones you configure here.
Primary sources: oig.hhs.gov/exclusions for the Bulletin and the LEIE, exclusions.oig.hhs.gov for the searchable database, and sam.gov for federal exclusion records. Nothing on this page is legal advice.
Automated screening, human determination.
The machine searches
Names go out against the lists in scope and the responses come back into the run. This part is mechanical and there is no reason a person should be typing names into three websites.
A person decides
A name match is not an identification. RIEL does not decide whether a name on the OIG exclusion list is your employee. That determination reaches a person, with the evidence attached, and their conclusion is recorded with their name on it.
The record survives both
The run, the hit, the reasoning and the disposition stay together. A year later the answer to “why was this cleared?” is a record and not a reconstruction.
What RIEL changes
- The screening cycle is a record, not a folder: scope, lists, results and dispositions held together.
- Nobody retypes a roster into three government websites once a month.
- Every match reaches a person with the evidence attached, and their determination is stored with their name and the date.
- Evidence for a given month is retrievable as it stood that month, rather than reassembled from what the lists say today.
- A screening gap surfaces as a readiness finding, and a vendor or provider that has not been screened is visible in the module that needs it.
- Providers, employees and contracted vendors are screened from the same place, which is where scope usually leaks.
What it does not
- It does not determine identity. A match on a common name is a lead, not a finding, and the system will not close that gap for you.
- It does not decide your screening frequency or your scope. Federal guidance, your state agency and your contracts do; you configure them here.
- It does not report to the OIG, to CMS or to anyone else on your behalf. Self-disclosure and repayment are decisions with legal consequence and they stay with you and your counsel.
- It is not legal advice, and the summary of the Special Advisory Bulletin on this page is not a substitute for reading it.
- It does not screen lists you have not told it to screen. There is no hidden “all applicable lists” setting — scope is explicit, because scope is the part that gets audited.
Scope is where screening programs usually fail.
Most centers screen their clinical providers. Fewer screen every employee. Fewer still screen contracted vendors, locum coverage, board members and the billing service — and those are precisely the relationships an exclusion reaches through.
Because RIEL already holds the provider file, the employee record and the vendor side of contracts, scope is a question of what you include rather than a question of assembling a list first. That is a smaller change than it sounds and it is usually the one that matters.
The same names carry into credentialing and payer enrollment, so an exclusion hit is not something that has to be remembered in three places.
Could you produce last December's screening run today?
Not the list as it stands now — the run as it stood then, with the dispositions and the names attached. If the answer takes more than a few minutes, that is the gap worth looking at.