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
- OIG's LEIE: everyone OIG has excluded from federal health care programs. OIG recommends it as the primary source for OIG exclusions.
- SAM.gov exclusions: run by the General Services Administration. It includes OIG's exclusions plus debarments by other federal agencies. OIG notes it can't impose penalties for employing someone who is only debarred, but some brokers and contracts ask for a SAM check anyway; Colorado's NEMT driver roster, for one, lists SAM exclusion screening.
- State Medicaid lists: some states keep their own exclusion lists. CMS told states with such lists to remind providers to search the state list whenever they search the LEIE. Check the list for each state where you work.
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
- Person's full legal name, plus any former names (maiden or prior married names).
- Date of birth and role (aide, nurse, driver, office staff, contractor).
- List checked: LEIE, SAM.gov, or the state list by name.
- Date of the search and who ran it.
- Names searched, including each part of a hyphenated last name.
- For a downloaded file: which month's file or supplement you used.
- Result: no match, or possible match.
- Proof saved: file name of the printout or PDF. For LEIE online searches, use OIG's Print Search Results button.
- For a possible match: date of Social Security number verification, the result and who reviewed it.
- Action taken, if any, and the date of the next check.
Monthly summary row
- Month checked and the date OIG's list was last updated.
- Number of people checked, and the lists checked.
- Possible matches found, and how each was resolved.
- Reviewer name, signature and date.
How to run the LEIE search so it holds up
- Online, you can search up to five names at a time. For a large staff, download the full LEIE file each month or add OIG's monthly supplement files to your copy.
- Enter only the first few letters of the first and last names to catch spelling differences.
- Search former names too. The LEIE shows only the name OIG knew when it excluded the person.
- Search a hyphenated name under each last name and the full name.
- The downloadable file has no Social Security numbers, so any possible match must be verified in the online search. OIG says a matching first and last name alone isn't enough.
- Print with OIG's Print Search Results button. OIG says the browser's print function won't work.
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
- HHS-OIG: Exclusions Program
- HHS-OIG: Updated Special Advisory Bulletin on the Effect of Exclusion (2013)
- HHS-OIG: LEIE Quick Tips and Instructions
- HHS-OIG: Exclusions FAQ
- CMS State Medicaid Director Letter SMDL #09-001 (PDF)
- 42 CFR 455.436: Federal database checks
- Colorado HCPF Operational Memo OM 26-029 (PDF)
- SAM.gov