A monthly check has come back with a name on one of your records that resembles a name on a public list. This is a normal thing to handle, it happens to organizations running a working compliance program, and there is a defined path through it.
Take the first sentence seriously before anything else: what you have is a potential match — verification required. It is not a finding about the person, and it is not a reason to change anything about your relationship with them today.
Why a name alone settles nothing
Public exclusion lists carry limited identifying detail. A comparison of names — even a name plus a state, even a name plus a professional category — tells you that two records resemble each other. It does not tell you they describe the same person. Common names produce potential matches routinely, and a system that presented one as a conclusion would be wrong a meaningful share of the time.
That is why no automated result here, or anywhere in Exclia, states more than "potential match — verification required". The confirmation is a human step, and it is a short one.
Step 1 — Confirm identity on the OIG's own tool
The OIG runs an online searchable exclusions database with a verification step: you enter the Social Security number or Employer Identification Number of the person or organization you are asking about, and the tool tells you whether it matches the record you are looking at.
Two things follow from that design.
The confirmation belongs on the OIG's tool, not with a vendor. Exclia never asks you for a Social Security number, and no screening service needs one to do its job. Only the outcome of your check comes back into your records.
Keep what you saw. The OIG's guidance asks providers to keep documentation of the search and of any further searches used to verify a potential name match. A dated screen capture of the verification result is the artifact an auditor will ask for later.
Step 2 — Note which list the record came from
The route to certainty differs by source.
- LEIE — the federal list published by the OIG. Verify through the online tool above.
- SAM — the System for Award Management record. Its entries carry their own identifiers and reference numbers; the exclusions records on sam.gov are the authority for what a SAM entry says.
- A state Medicaid list — each state publishes its own, with its own verification contact. Our state requirement guides link the official list for every state we have published, along with what that state requires of providers.
Step 3 — Write down how you decided
Whatever the outcome, the record of the review is the part that has value in six months: who looked, when, what they compared, and what they concluded. Exclia asks for a short reasoning note at exactly this point and keeps it as a timestamped, read-only entry beside the evidence that was on screen at the time — a correction adds a new entry rather than overwriting the first.
If you are doing this in a spreadsheet instead, capture the same four things. A resolved match with no reasoning is indistinguishable, later, from a match nobody looked at.
If the identity is not confirmed
Record that conclusion with the reason, and close it. Keep the record: the same name will resemble the same list entry next month, and the note you wrote today is what stops the following eleven reviews from starting over.
If the identity is confirmed
Then the payment rule described in the requirements explainer is the thing to work from: no federal health care program payment may be made for items or services furnished by a person on the list, or directed or prescribed by a listed physician (42 C.F.R. § 1001.1901), and that reaches administrative and management services and salary paid from program funds as well as clinical work.
Two pieces of information are worth having in front of whoever makes the decision.
The OIG publishes information about its voluntary self-disclosure process, at oig.hhs.gov/compliance/self-disclosure-info. Organizations that identify potential fraud or penalty exposure involving federal health care programs use it to disclose the conduct themselves. Whether it applies to your situation is a question for your counsel.
Dates matter to the analysis. The date the listing took effect, the date of your last documented check, and the dates of any claims in between are what an assessment of exposure is built from. Your screening history is where those dates come from, which is one reason a check that records its own list version and date is worth more than a check that does not.
What we will not do is tell you what to do about the person or the contract. That decision belongs to your organization and its own counsel, taking in facts we cannot see. This page, and everything Exclia produces, is information for your compliance file — not advice on any relationship you have with anyone.
Where to look next
If you want to run a single name against the federal lists right now, the free checker searches the LEIE and SAM and shows the exact list version behind the result. For what the underlying list actually is, read what is the LEIE.