Understanding Exclusion Checks: A Simple Guide for Small Practices
- Alicia Shickle
- Mar 26
- 2 min read
Ensuring compliance with federal and state regulations is a crucial part of running a healthcare practice, but one area that often gets overlooked is exclusion checks. If your practice submits claims to federally funded healthcare programs like Medicare or Medicaid, failing to check for exclusions can lead to serious consequences, including fines and potential loss of reimbursement. Though it may seem daunting, It can be a simple process for a small practice once you have a structured plan in place.
What is an Exclusion Check?
An exclusion check is the process of verifying whether an individual or entity has been barred from participating in federally funded healthcare programs. The Office of Inspector General (OIG) and other agencies maintain databases of individuals and businesses that are excluded due to fraud, abuse, or other violations.
Who Needs to Be Screened?
Your practice should conduct exclusion checks for:
New hires (before they start working)
Current employees (monthly or quarterly checks recommended)
Contractors and vendors (especially those involved in billing, coding, or patient care)
Temporary staff and volunteers (if they interact with federally funded programs)
Excerpt from https://oig.hhs.gov/exclusions/
"OIG maintains a list of all currently excluded individuals and entities called the List of Excluded Individuals/Entities (LEIE). Anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties (CMP). To avoid CMP liability, health care entities should routinely check the list to ensure that new hires and current employees are not on it."
How to Perform an Exclusion Check
Go to the OIG List of Excluded Individuals/Entities (LEIE): Visit https://exclusions.oig.hhs.gov and search by name.
Check the SAM (System for Award Management) database: Visit https://sam.gov to verify exclusion status.
Check your state’s Medicaid exclusion list: Many states have their own exclusion databases that should be reviewed in addition to federal lists.
Document your findings: Maintain a log of all exclusion checks, including names searched, dates checked, and outcomes.
Take action if necessary: If an individual or entity is found on an exclusion list, they should not be employed or engaged in activities related to federally funded healthcare programs. (We recommend checking with your legal team or a compliance expert)
How Often Should You Check?
Before hiring a new employee or engaging a contractor/vendor
At least monthly for all current staff and contractors
Before renewing contracts with vendors or outsourced billing companies
Why It’s Important
Exclusion checks help protect your practice from legal and financial risks. Hiring or working with an excluded individual could result in hefty fines, penalties, and even the loss of your ability to participate in government-funded healthcare programs. Ensuring regular screening is a simple but vital part of compliance.
Free Download for Our Compliance Members!
To help small practices stay organized, we’ve created a Monthly Exclusion Check Tracker and a New Hire Exclusion Check Form for our VIP Compliance Members. These tools will help you document your screenings efficiently and stay compliant with federal regulations.
👉 Members: download your free exclusion check template today!
Monthly Exclusion Checks Included for our VIP Compliance Members!
To help small practices stay organized, we’ve included Monthly Exclusion Checks as part of our VIP Compliance Membership so you can take that right off your plate!
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