Healthcare exclusion screening checklist

Assign a screening owner and a reviewer for unresolved results.

Reconcile the roster with current workforce and vendor records; record additions, departures, and the roster version.

Include relevant contracted and support roles, based on whether their work is paid directly or indirectly by federal healthcare programs.

Collect legal names, known former names or aliases, and available identifiers through approved internal channels.

Include the OIG LEIE for OIG exclusions. Identify any additional state Medicaid, payer, or contract sources that apply and record the authority for each.

Record each source’s URL, data edition or update date, and the date searched. A failed or unavailable source is an incomplete check, not a clear result.

Set the next run date and record its basis: organizational policy, agency guidance, or a specific state or contract requirement.

Screen prospective employees, contractors, and in-scope vendor personnel before employment or contracting; record the check date and onboarding decision.

When relying on a staffing agency or vendor to screen, obtain and retain documentation showing who was checked, when, and against which sources; validate that the agreed screening occurred.

Assign potential matches to a reviewer and escalate unresolved cases before approving affected work. Add engaged people and entities to the recurring roster.

Name a run owner, backup, match reviewer, and compliance escalation owner; document responsibilities and follow-up deadlines.

Schedule recurring checks using the documented timing basis. OIG recommends monthly LEIE checks; verify any state, payer, or contract duties separately.

Reconcile screened counts with the roster and selected sources. Investigate missed runs, failed searches, and stale data; repeat affected checks and track open reviews.

Search each selected source using its official instructions, including relevant name variations.

Save the initial search results and any follow-up searches, including searches with no results.

If using downloaded LEIE data, use a current full file or correctly apply both exclusion and reinstatement supplements; record which version was used.

Treat a matching name as a possible match pending identity review; compare available identifying details.

For a possible LEIE match, use OIG’s online SSN or EIN verification. If identity remains uncertain, contact OIG for assistance and keep the case unresolved.

Record the reviewer, evidence, disposition, and review date. Escalate confirmed or unresolved cases to the designated compliance owner for decisions about affected work, payments, and reporting.

Do not infer reinstatement from an elapsed exclusion period; verify current status with the issuing authority.

List missing roster entries, unavailable sources, and open match reviews; assign an owner and follow-up date for every gap.

Retain the roster version, source versions, search evidence, and review decisions under your organization’s retention and access policies.

Record reviewer sign-off and the next screening date. A run with open gaps should remain marked incomplete.

Index the roster snapshot, source register, search results, match decisions, vendor evidence, and sign-off by run date in an approved evidence location.

Walk through a sample record from roster to search to disposition so a reviewer can reconstruct the check, including any verification evidence.

Include incomplete runs, outstanding cases, corrective actions, owners, and due dates. Confirm access controls and the applicable retention policy; do not treat a downloaded report as compliance certification.