Monthly exclusion screening guide
Plan recurring healthcare exclusion checks: choose sources, maintain a roster, review matches, monitor missed runs, and preserve audit evidence.
Content review and source verification
- Last reviewed
- Last verified
- Content owner
- Exclia content team
- Review cadence
- Every 90 days
- Next review due
Why repeat screening?
A previous check describes an earlier point in time. Your roster and government lists change. Recurring screening helps identify new potential exclusions among current staff, contractors, and vendors whose work may be paid directly or indirectly by federal healthcare programs. Pair it with checks before engagement and when relevant information changes; a monthly run should not delay review of a known concern.
Legal requirements and operational best practice
Legal requirements: 42 CFR § 455.436 places monthly LEIE and EPLS database-check duties on state Medicaid agencies for specified providers and associated people. That agency rule does not create a universal monthly workforce-screening mandate for every healthcare employer. Provider duties can differ by state, program, payer, and contract.
Read the federal Medicaid agency ruleOperational best practice: OIG recommends monthly LEIE checks to reduce exposure because its list is updated monthly. Document your organization’s schedule and distinguish an internal monthly policy from a binding requirement. Confirm any stricter obligations with your compliance owner and the relevant official sources.
Read OIG’s screening frequency guidanceReview state requirement guidesChoose and maintain source coverage
Use the OIG LEIE for OIG exclusions. Determine which state Medicaid exclusion or termination lists and additional federal, payer, or contract sources apply. SAM contains federal exclusion and debarment records with different scopes; it does not replace the LEIE. A search of one list does not establish clearance under every program.
Keep a source register with the reason each source applies, its official URL, update timing, data version, and date checked. Review it when you enter a new state or contract. For downloaded LEIE data, refresh the full file or correctly apply both exclusion and reinstatement supplements. Log an unavailable or stale source as a gap requiring follow-up.
Follow OIG’s search and download instructionsCheck Exclia’s current source coveragePractical monthly workflow checklist
Assign a run owner, a backup, a match reviewer, and escalation deadlines. The following checklist is an operational template; adapt its scope and timing to your obligations.
Reconcile your monitored roster with current staff, contractor, and vendor records. Record additions, departures, relevant aliases, and the roster version. Include support roles based on their work and funding.
Confirm the required source set and current data versions. Record the screening date and why your chosen cadence applies.
Run every in-scope record against each selected source. Retain search evidence, including no-result searches, and reconcile the number screened with the roster count.
Queue potential matches for identity review. Assign a reviewer and due date; record the evidence, decision, and any escalation.
Check run completion, failed searches, missing records, source gaps, and outstanding reviews. Assign follow-up owners; do not mark gaps as clear results.
Save the run evidence and reviewer sign-off in an approved system. Mark incomplete runs explicitly and schedule the next check and outstanding follow-ups.
Monitoring needs human oversight
A scheduled job is only one part of monitoring. Check that each run actually completed, used current sources, and covered the intended roster. Route alerts to a named owner and backup, track unresolved cases, and investigate missed runs promptly. If a source fails, preserve the failure record and repeat the affected checks when it becomes available.
Exclia supports monthly roster screening, potential-match email alerts, screening history, and monthly audit reports. Review source coverage and plan limits before relying on it, and keep your roster and reviewers current. Automation supports the process; your team still decides how to resolve matches and meet applicable duties.
Explore Exclia’s monthly monitoring workflowCompare ongoing screening plans and report capabilitiesHandle matches and escalations
A similar name is a potential match, not a confirmed identity. Compare available details and use OIG’s online SSN or EIN verification for possible LEIE matches through approved channels. If identity remains uncertain, seek agency assistance and leave the review open. Keep sensitive identifiers out of this website and the downloadable worksheet.
Document who reviewed the case, the verification evidence, the disposition, and the next action. Escalate confirmed or unresolved cases promptly to compliance and legal counsel to assess affected work, payment, reporting, and remediation. An elapsed exclusion period alone does not establish reinstatement; verify current status with the issuing authority.
Follow the potential-match review workflowKeep evidence that explains the run
Preserve the roster snapshot, names searched, sources and versions, run timestamps, search results, verification evidence, review decisions, and sign-off. Include failures, retries, unresolved cases, follow-up owners, and the next scheduled run. When a vendor performs checks, retain evidence of who was screened, when, and against which sources.
Store records with controlled access and retention based on applicable law, contracts, and your records policy. A report should let a reviewer reconstruct what was checked and why a possible match was cleared. A completed run or downloaded report does not certify compliance or resolve open cases.
Official sources
- OIG: Effect of Exclusion — screening scope, frequency, and documentation
- OIG: LEIE Quick Tips & Instructions — searching and identity verification
- OIG: Exclusions FAQs — possible matches and reinstatement
- 42 CFR § 455.436 — federal database checks by state Medicaid agencies