Stop These Common OIG Exclusion Screening Mistakes in 2025

A practice manager in Florida recently called us after a routine internal audit turned up a nightmare. They’d been employing a part-time physical therapist for three years. The PT was great. The patients loved him. But his name was on the OIG’s List of Excluded Individuals and Entities (LEIE). Because they hadn't checked the list properly, every single claim billed under that PT’s NPI for thirty-six months was technically a false claim. The OIG doesn't care if you didn't know; they care that you didn't look.

If you think a quick search of the SAM.gov portal once a year keeps you safe, you’re sitting on a regulatory time bomb. In this guide, we’re breaking down the common OIG exclusion screening mistakes for medical practices and how to avoid them in 2025 so you don't end up writing a six-figure check to the government.

The "One and Done" Fallacy During Onboarding

The most frequent mistake we see is treating exclusion screening as a checkbox only for new hires. You run the check during the initial credentialing phase while you're gathering their CAQH ProView details and filing the CMS-855I. Then, you never look at it again.

People get excluded for things that happen after they start working for you. A nurse might lose their license due to a substance abuse issue three months into the job. A biller might get flagged for a default on a HEAL loan. If you aren't checking every month, you’re flying blind. The OIG updates the LEIE monthly. Your screening schedule needs to match that cadence. If someone falls onto the list on the 10th of the month and you bill for them on the 15th, you are liable.

Searching Only the OIG LEIE and Ignoring SAM.gov

Many offices think the LEIE is the only list that matters. It isn’t. While the OIG manages the LEIE, the General Services Administration (GSA) manages the System for Award Management (SAM).

Why does this matter? The LEIE focuses on healthcare-related exclusions (like Medicare fraud). SAM includes debarments from all federal procurement and non-procurement programs. If a vendor or an employee is barred from federal contracts for a reason outside of direct healthcare fraud, they will show up in SAM but potentially not in the LEIE.

We see this fail most often when practices forget to screen their vendors. If your medical supply company or your outsourced IT firm is on the SAM debarment list, and you’re paying them with federal funds (which, let’s be honest, is almost every dollar in a Medicare-heavy practice), you’ve got a compliance breach.

Missing the "AKA" and Name Variation Trap

Software is only as smart as the data you give it. If you search for "Jonathan Smith" but the provider is listed as "Jon Smith" or "J. R. Smith," a basic search might return zero results.

We’ve seen providers change their last names after a marriage and the LEIE entry remains under the maiden name for months. You must screen every name an individual has ever used. This includes:

• Maiden names
• Hyphenated names
• Common nicknames used professionally
• Middle initials

If you aren't cross-referencing the Social Security Number (SSN) or Employer Identification Number (EIN) to verify a "hit," you’re either clearing people who should be blocked or wasting hours chasing ghosts.

Forgetting the Non-Clinical Staff

This is the big one. Practice managers often assume exclusion screening only applies to "providers"—the MDs, PAs, and NPs.

The OIG’s reach is much wider. The rule is simple: if the person’s salary or the services they provide are funded, directly or indirectly, by a federal healthcare program, they must be screened.

This includes:

1. Front desk receptionists
2. Medical billers and coders
3. Janitorial staff (if employed by the practice)
4. Volunteers
5. Board members and owners

If your biller is excluded and they touch a Medicare claim, that claim is tainted. Period.

Lack of Documentation and the "Search Log" Gap

Let's say you actually do the screenings every month. You sit down, type in the names, see nothing, and go back to work. Two years later, the OIG knocks. They want proof you screened in July 2023.

If you didn't print the "No Results Found" screen or save a time-stamped digital log, you have no proof. In the eyes of an auditor, if it isn't documented, it didn't happen.

Avoid this by creating a monthly compliance folder. Every month, run your roster, export the results, and have the compliance officer sign off on the report. This turns a frantic search for old data into a five-minute pull from your files.

Using Outdated Roster Data

Your screening is only as good as your HR roster. We often find that practices are screening an old list of employees. A per-diem nurse who hasn't worked in six months might still be on the list, while the new tech who started last Monday isn't.

Before you run your monthly check, reconcile your payroll list with your credentialing list. If you use a platform like Availity or a specific credentialing software, ensure the "active" status is accurate. You don't want to pay for screenings you don't need, but you definitely don't want to miss the new hire who slipped through the cracks during a busy week.

Checklist for 2025 OIG Compliance

To keep your practice out of the crosshairs, implement this workflow immediately:

• Monthly Cadence: Set a recurring calendar invite for the 15th of every month (giving the OIG time to post their monthly update).
• Comprehensive Roster: Include every person on payroll, every owner, and every primary vendor.
• Multi-List Search: Check the OIG LEIE, SAM.gov, and your specific State Medicaid exclusion list (many states maintain their own).
• SSN Verification: If you get a name match, use the SSN verification tool on the OIG website to confirm if it’s actually your employee.
• Hard Evidence: Save a PDF of every search result, including the "No Results Found" page.
• Contractor Clauses: Update your vendor contracts to require them to certify they aren't excluded and will notify you immediately if their status changes.

How to Handle a Positive Hit

What happens if you actually find someone? Do not panic, but do not wait.

1. Immediate Suspension: Remove the individual from all duties involving federal programs. In a small practice, this usually means suspending them entirely.
2. Verify the Match: Double-check the SSN. Sometimes names are identical but the individuals are different.
3. Consult Legal Counsel: You need to determine the "look-back" period. How much money was received for services this person was involved in?
4. Self-Disclosure: The OIG has a Provider Self-Disclosure Protocol. Reporting yourself is painful, but the fines are significantly lower than if they find you first.

Screening for OIG exclusions isn't about clinical quality; it's about protecting your right to get paid. One oversight can lead to an administrative freeze on your Medicare payments via the MAC (Medicare Administrative Contractor), effectively killing your cash flow overnight.

If you’re still doing this manually in Excel for a 50-person practice, it's time to automate. The risk of a manual data entry error is simply too high for the $10,000+ per-item penalty you'll face. Audit your process this week—before the OIG does it for you.