Short answer: before you bring someone on, and every month after that. That is the interval the HHS Office of Inspector General points to, the one CMS asked state Medicaid programs to require, and the one most compliance programs adopt. The reasons behind it matter, because they also tell you what a monthly check has to record to be worth anything.
Why monthly, and not quarterly or yearly
The interval comes from how often the list changes. The OIG adds names to the List of Excluded Individuals and Entities (LEIE) and removes reinstated ones every month, and publishes the changes as monthly supplement files.
The OIG's 2013 Special Advisory Bulletin draws the conclusion directly: because the LEIE is updated monthly, "screening employees and contractors each month best minimizes potential overpayment and CMP liability." A check every quarter leaves up to two monthly updates unread; a yearly check leaves eleven.
Recommendation or requirement?
Both, depending on where you sit.
Federally, for providers, it is a recommendation. No federal rule tells a provider to search the LEIE on a fixed schedule. The bulletin says providers "may decide how frequently to check the LEIE" — and then recommends monthly. What is fixed is the payment rule underneath: no federal health care program pays for items or services furnished by a person on the list, and penalties can follow where the organization knew or should have known.
For state Medicaid agencies, monthly is a rule. Under 42 C.F.R. § 455.436, the state agency must check federal databases, including the LEIE and SAM, for its enrolled providers no less frequently than monthly.
For many Medicaid providers, the state makes it binding. In SMDL #09-001, CMS told states they "should require providers to search the HHS-OIG website monthly to capture exclusions and reinstatements that have occurred since the last search." Many states did, through provider agreements or their own regulations, and several add their own state list to the check. Our state requirement guides cover each state with its own sources.
What a monthly check should cover
- Every list that applies to you. The LEIE, SAM.gov, and your state's Medicaid list where it keeps one. They are separate sources, published on separate schedules; a search of one is not a search of the others. The exclusion lists directory lists every one.
- Everyone whose work ends up in something you bill. Staff, contractors, vendors, owners and managing employees — see exclusion screening for contractors and vendors.
- Everyone, every month. A monthly program that screens new people monthly and current people yearly is a yearly program for most of your list.
What a monthly check should record
The bulletin asks providers to keep documentation of the search performed and of any further searches used to verify a potential name match. In an audit, a record is useful when it answers three questions: who was checked, against which version of which list, and on what date. A name that matches an entry is a potential match — verification required, using identifiers such as NPI, date of birth or the SSN/EIN verification on the OIG's online search — and the record should show how it was resolved.
Doing it monthly without doing it by hand
A monthly check by hand means searching every name on every list, after every update, and keeping the screenshots. That is manageable for a handful of people and becomes the job of someone's week as the list grows.
Exclia re-screens everything you monitor on the day of the month you choose, against every list in one run, records the list versions each run used, and puts any potential match in front of a person with the evidence beside it. You can check one name for free first, or see how it compares with the free OIG search.
This page explains published requirements, with the sources linked below so you can read them yourself. It is not legal advice.