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Monthly Exclusion Check Log: What to Record for OIG, SAM and State Lists

Short answer: OIG updates its List of Excluded Individuals/Entities (LEIE) every month and says screening employees and contractors each month best minimizes overpayment and penalty risk. OIG also says to keep documentation of each name search. A log with one row per person, per list, per month, plus the saved search result, is that documentation. This page lists the columns to use.

Updated October 15, 2026 · Checked against the official sources listed at the end

Which lists to check

Tracking staff credentials by hand? Pact keeps every worker's credentials checked, reminds workers before anything runs out, and checks everyone against OIG's exclusion list every month, with a dated record of each check. $10 per active worker a month, $250 minimum, first month free. Nursing homes · Home care & hospice · Staffing agencies · Free OIG name check · Get my price

Why monthly

OIG's 2013 Special Advisory Bulletin says providers aren't required by statute or regulation to check the LEIE and may decide how often. It then says OIG updates the LEIE monthly, so monthly screening best minimizes potential overpayment and civil money penalty liability. OIG's exclusions page says anyone who hires someone on the LEIE may be subject to civil money penalties.

CMS's 2009 letter to state Medicaid directors (SMDL #09-001) says states should require providers to search the OIG site monthly. State Medicaid agencies themselves must check the LEIE and EPLS, now part of SAM, no less than monthly for the providers they enroll (42 CFR 455.436). Your state Medicaid rules, broker manual or facility contracts may make monthly checks a requirement for you.

Printable log layout: one row per person, per list

Monthly summary row

How to run the LEIE search so it holds up

If a name matches

Verify it with the person's Social Security number in OIG's online search before acting. If the match is confirmed, OIG's FAQ says to read the 2013 bulletin, and if you already employed the person, to look at OIG's Self-Disclosure Protocol. CMS also told states to require providers to report any exclusion they find to the state right away, so check your state's instructions. A health care attorney can help with next steps.

How Pact helps (and what it doesn't do)

Pact checks every active staff member or driver against OIG's list each month, plus the Medicaid exclusion lists of the states you work in where the state publishes one as a file, and keeps a dated record of each check. The files have no Social Security numbers, so a possible match comes to you to verify. Pact doesn't check SAM.gov. For states whose list can't be downloaded, the portal links the list for you to check by hand. $10 per active staff member a month ($250 minimum) for healthcare, or $15 per driver ($99 minimum) for NEMT.

Common questions

Is a monthly OIG exclusion check required by law?

OIG says no statute or regulation requires providers to check the LEIE, but it recommends checking monthly. CMS has told states to require monthly searches by Medicaid providers, and some brokers and facility contracts require them too.

What is the difference between the LEIE and SAM?

The LEIE lists only OIG's exclusions. SAM includes OIG's exclusions plus debarment actions by other federal agencies.

What proof should I keep of an exclusion check?

OIG says to keep documentation of the initial name search, such as a printed screen of the results, and of any further searches done to verify a possible match.

Can I check the whole staff at once?

Online, up to five names per search. For more, download OIG's full list or its monthly supplements and compare it to your roster, then verify any possible match online with the Social Security number.

Sources

Related guides

Run a healthcare staffing agency, nursing home or home care agency? Pact keeps every worker's credentials checked, reminds workers before anything runs out, and shares packets with facilities without a login. $10 per active worker a month, $250 minimum, first month free. Staffing agencies · Nursing homes · Resident vaccine tracking · Home care & hospice · NEMT driver files · Free OIG name check · Get my price · 901-666-6970