An OIG/SAM background check is a search of two federal databases — the HHS Office of Inspector General’s List of Excluded Individuals and Entities (LEIE) and the exclusion records on SAM.gov — to confirm that a person or business is not barred from participating in federally funded programs. Healthcare providers, federal contractors, and grant recipients are legally required to run these checks before hiring or contracting with someone, and to keep checking on a recurring basis. The search itself takes only a few minutes. Missing an excluded person on your payroll can cost up to $20,000 for each item or service they bill, plus triple the amount claimed.1Office of the Law Revision Counsel. 42 USC 1320a-7a – Civil Monetary Penalties
Who Has to Run One
Healthcare Organizations
Any provider that bills Medicare or Medicaid must verify that every person involved in delivering or supporting care is not on a federal exclusion list. That reaches well past physicians and nurses. Billing staff, lab technicians, pharmacists, administrative employees, contractors, and vendors all fall under the requirement if any part of their compensation flows from federal healthcare dollars, even indirectly.2Office of Inspector General. Exclusions Program
Federal Contractors
Companies performing federal contracts must screen subcontractors before entering into any subcontract worth more than $35,000, other than for commercially available off-the-shelf items. The subcontractor has to disclose in writing whether it or any of its principals are debarred, suspended, or proposed for debarment.3eCFR. 48 CFR Part 9 Subpart 9.4 – Debarment, Suspension, and Ineligibility
Grant and Loan Recipients
Organizations receiving federal grants, cooperative agreements, or loans must verify that anyone they do business with at the next lower tier is not excluded or disqualified. Before entering a covered transaction, the participant checks SAM.gov exclusions, collects a written certification, or adds a compliance clause to the agreement.4eCFR. 2 CFR Part 180 – OMB Guidelines to Agencies on Governmentwide Debarment and Suspension
The Two Databases
LEIE
The List of Excluded Individuals and Entities is the healthcare-specific database maintained by the HHS Office of Inspector General. It lists every individual and entity currently barred from Medicare, Medicaid, and every other federally funded health program. An excluded person cannot receive any federal healthcare payment for items or services they furnish, order, or prescribe. OIG updates the LEIE monthly, and each month’s file reflects the exclusion actions and reinstatements processed the prior month.5U.S. Department of Health and Human Services. LEIE Database and Supplement Downloads
SAM.gov
SAM is the government-wide system managed by the General Services Administration. It tracks debarments, suspensions, and proposed debarments across every executive branch agency. Where the LEIE focuses on healthcare misconduct, SAM covers a wider set of problems: contract fraud, tax delinquency, procurement violations, and other conduct that makes a person or entity ineligible for government business. Clean results on one database do not carry over to the other. Anyone who needs a complete picture of federal eligibility searches both.6SAM.gov. System for Award Management
How to Run the Check
Searching the LEIE
The LEIE search tool is at exclusions.oig.hhs.gov. Enter the individual’s full legal name or the entity’s formal business name. Run any known aliases or “doing business as” names as separate searches; the database will not cross-reference them automatically.7Office of Inspector General. Search the Exclusions Database
If no records come back, the person is clear on the LEIE. If a name match appears, stop and verify. The results page shows potential matches with identifying details like city and state, but a shared name is not proof of identity. Click through to the verification step and enter the individual’s Social Security Number or the entity’s Employer Identification Number. That is what confirms whether the match is actually your applicant or someone unrelated with the same name.8Office of Inspector General. LEIE Quick Tips and Instructions
This is the step organizations most often skip, and it is exactly the step auditors check for. A name-only search without SSN or EIN verification does not satisfy the compliance requirement.
Searching SAM
SAM.gov has a dedicated exclusion search. Enter the individual or entity name and, if available, the Unique Entity Identifier. The workflow mirrors the LEIE: a clean result means no current government-wide debarment or suspension, and a match requires further verification to confirm identity. Organizations working in both healthcare and procurement should search both databases for every person they screen.6SAM.gov. System for Award Management
Bulk Screening for Larger Workforces
Organizations with sizable payrolls can download the full LEIE database as a CSV file and run it against their own employee and vendor rosters. OIG posts an updated full file each month, plus a smaller supplement file that captures only that month’s additions and reinstatements — useful for ongoing monitoring once the full database is in place.5U.S. Department of Health and Human Services. LEIE Database and Supplement Downloads
How Often to Screen
Run an initial check during the hiring or contracting process, before the person starts work or receives any federal payment. After that, OIG expects monthly LEIE screening of all existing employees, contractors, and vendors. Monthly is the standard because the LEIE itself is updated monthly, and an annual-only check leaves as much as eleven months in which a newly excluded person could be billing federal programs on your dime.2Office of Inspector General. Exclusions Program
For federal contractors and grant recipients, 2 CFR Part 180 requires verification before entering any covered transaction but does not set a monthly cadence. In practice, many organizations screen monthly across the board anyway, because the cost of a monthly database check is trivial next to the penalty exposure.4eCFR. 2 CFR Part 180 – OMB Guidelines to Agencies on Governmentwide Debarment and Suspension
What It Costs to Miss Someone
Two penalty tracks apply, and they stack quickly.
An employer or entity that arranges for or contracts with an excluded individual to provide items or services reimbursed by a federal healthcare program faces civil monetary penalties of up to $20,000 for each item or service furnished during the exclusion period.1Office of the Law Revision Counsel. 42 USC 1320a-7a – Civil Monetary Penalties
The excluded person who submits or causes claims to be submitted faces a separate penalty of up to $10,000 per item or service, plus an assessment of up to three times the amount claimed. OIG can also extend that person’s exclusion period on top of the financial penalties.9Office of Inspector General. The Effect of Exclusion From Participation in Federal Health Care Programs
If You Find a Match on Your Payroll
Finding an excluded person already working for you triggers immediate obligations. The employee or contractor must be removed from any role where federal healthcare dollars fund their work. In practice, that usually means termination or reassignment to a position with no connection to federally funded programs.
Next, determine whether any federal claims were submitted for services the excluded person provided. If they were, the organization likely has an overpayment that must be reported and returned. Federal law generally requires identified overpayments to be returned within 60 days.
OIG runs a Provider Self-Disclosure Protocol for healthcare entities that discover potential fraud, including the employment of excluded individuals. It is a formal process for voluntarily reporting the problem and negotiating a resolution. Submissions use a dedicated form on the OIG website and must follow the requirements in the Self-Disclosure Protocol document. Entities already under an Integrity Agreement should contact their OIG monitor directly instead of using the standard submission.10Office of Inspector General. Health Care Fraud Self-Disclosure
Self-disclosure does not guarantee a favorable outcome, but it tends to produce lower penalties than what OIG would seek after finding the problem on its own. It also suspends the 60-day overpayment return obligation while the settlement process is underway, which lets the organization calculate the full scope before repaying.
Records to Keep
Documentation is what proves the check happened. For every search, save a screenshot or printout showing the date, the name searched, and the result. That applies to initial pre-hire screenings and to every monthly recheck.
When a name match appears but SSN or EIN verification clears the individual, save the verification result too. Auditors want to see not just that you searched, but that you completed the identity confirmation step. These records back up your due diligence during CMS audits, OIG investigations, or state Medicaid reviews.
Federal healthcare documentation rules generally require at least six years of retention, and many compliance professionals recommend seven years to align with longer audit cycles. Keep the full paper trail: monthly search logs, pre-hire screening results, verification outcomes, and any corrective-action documentation from a discovered match.
Mistakes That Create Exposure
The most dangerous screening failure isn’t a missed check. It’s a careless one. Running a name-only search and calling it done is nearly as risky as not searching at all, because any unverified name match leaves your organization unable to prove compliance.
A second common gap: screening employees but forgetting contractors, temporary staff, and vendors. The exclusion rules apply to anyone whose compensation touches federal funds, regardless of employment classification. A staffing-agency nurse or an outsourced billing company falls under the same requirement as a full-time hire.
Organizations also get caught searching only one database. A person can be debarred on SAM.gov for procurement fraud without appearing on the LEIE, and the reverse is just as true. Running both checks takes a few extra minutes and closes a gap that auditors already know to look for.