OIG Background Checks: Complete Guide for Healthcare Employers

An OIG background check is a screening process that searches federal exclusion databases to determine whether healthcare workers, contractors, and vendors are barred from participating in federally funded healthcare programs.

The OIG exclusion list—formally called the List of Excluded Individuals and Entities (LEIE)—is the official database of individuals and entities excluded from Medicare, Medicaid, and other federal healthcare programs. The US Department of Health and Human Services maintains this database and updates it each month.

Exclusion means the person or entity cannot bill or participate in federal healthcare programs. The LEIE includes exclusions for offenses such as healthcare fraud, patient abuse or neglect, and certain licensing violations.

The Office of Inspector General (OIG) oversees program integrity and enforces exclusions that apply to Medicare, Medicaid, and other federal healthcare programs. OIG screening differs from standard criminal background checks because it focuses specifically on healthcare program exclusions rather than general criminal history.

Organizations that employ excluded individuals risk losing their ability to receive Medicare and Medicaid payments. Generally, it’s recommended that employers search the OIG exclusion list monthly since it’s updated on a monthly cadence. 

Healthcare organizations often run both LEIE checks and SAM searches for more comprehensive compliance coverage.

Under Section 1128 of the Social Security Act, the Department of Health and Human Services (HHS) is mandated to exclude individuals or organizations for the following causes:

Healthcare organizations that also contract with federal agencies or receive grants typically check both databases to address healthcare program integrity and broader federal contracting requirements.

The Social Security Act defines two types of OIG exclusions based on the severity of the offense.

Mandatory exclusions are required by law for serious offenses and typically carry longer exclusion periods:

Permissive exclusions are imposed at OIG's discretion for lesser violations:

The duration of different exclusions varies significantly. Mandatory exclusions often last several years, while permissive exclusions may be shorter. Reinstatement is not automatic—excluded parties must apply to OIG and receive formal approval before resuming participation in federal healthcare programs.

Healthcare organizations that bill Medicare, Medicaid, or other federal programs face significant risks when they employ excluded individuals. OIG verification helps organizations maintain their program eligibility and avoid costly penalties.

The Centers for Medicare and Medicaid Services expect healthcare providers to screen their workforces to prevent billing violations. This includes employees, contractors, vendors, and volunteers who may be involved in federally reimbursed services.

Employing an excluded individual can result in substantial financial consequences:

Regular exclusion screening helps prevent individuals with histories of fraud, abuse, or serious professional misconduct from affecting patient care or billing operations. This reduces the risk of harm and maintains credibility with patients, payers, and regulators.

Federal regulations and compliance guidance establish expectations for initial and ongoing exclusion screening. Healthcare organizations typically develop screening policies that align with regulatory requirements and the update schedules of exclusion databases.

Section 1128 of the Social Security Act authorizes OIG to exclude individuals and entities from federal healthcare programs. The law defines mandatory and permissive exclusion categories and establishes that claims tied to services furnished, ordered, or prescribed by excluded parties are not payable under federal healthcare programs.

Covered entities—including providers, suppliers, managed care organizations, and their contractors—carry responsibility for screening to avoid employing or contracting with excluded parties.

When using third-party screening services for employment background checks, employers must follow the Fair Credit Reporting Act (FCRA). This includes providing disclosures, obtaining authorization from candidates to run a background check, and following adverse action procedures if screening results influence employers’ hiring decisions.

Guidance from the Equal Employment Opportunity Commission (EEOC) also applies to ensure screening practices are consistent, job-related, and non-discriminatory. For example, only screening candidates of a specific race or gender would be considered discriminatory; however, running driving record checks on all candidates considered for a driving role would be job-related and consistent.

Many states maintain separate Medicaid exclusion lists in addition to federal sources. Multi-state healthcare employers typically include relevant state lists alongside the LEIE and SAM in their screening programs.

Healthcare employers can perform OIG checks through manual database searches or professional screening services. Here's the step-by-step process:

Collect complete identifying information to ensure accurate database matching:

Access the official databases:

Professional screening services can automate searches across multiple databases and provide ongoing monitoring capabilities.

When the search returns potential matches:

Maintain comprehensive records including:

Implement ongoing monitoring to catch new exclusions:

Healthcare organizations can face serious consequences when they fail to screen candidates properly or ignore exclusion results.

Financial penalties can include:

Regulatory consequences may include:

Yes, you can search the OIG LEIE and SAM databases for free through their official government websites. However, many employers use professional screening services for automation, broader database coverage, and continuous monitoring capabilities.

Manual searches of government databases can be completed immediately if you have the necessary identifiers. Automated screening services typically return results within a few hours and can provide ongoing monitoring for new exclusions.

Remove the individual from any federally reimbursed duties immediately and consult with legal or compliance counsel to assess disclosure requirements, potential repayment obligations, and other compliance steps. Document all actions taken and follow your organization's compliance policy for next steps.

Checkr helps healthcare organizations maintain compliance through comprehensive exclusion screening. Our platform simplifies the complex process of OIG verification while providing the documentation and audit trails necessary for regulatory compliance.

Checkr provides automated OIG exclusion screening that includes LEIE checks, SAM searches, and monthly monitoring. The platform integrates with HRIS, ATS, and healthcare systems to centralize documentation and maintain consistent compliance workflows.

Organizations can streamline their healthcare sanctions screening process and reduce the administrative burden of manual database searches. Get started with Checkr to automate your OIG background screening program.

About the author

Karen Axelton writes about business topics and best practices. She has written hundreds of articles on business subjects, including background screening, hiring and employment trends, human resource management, and the use of technology in the workplace. Her work includes educational articles, e-books, white papers, and case studies.