Hotline [Healthcare Compliance Tips]
Management & Evaluations [Healthcare Compliance Tips]

Exclusion List [Healthcare Compliance Tips]

Hire vendors to ensure your employees are not on the OIG, GSA, or state exclusion list.

In this post, we will continue to discuss our findings from SAI Global and Strategic Management Services2019 Healthcare Compliance Benchmark Report.” They state:

29% of respondents use vendor sanction screening.

The OIG suggests that healthcare entities conduct monthly (routine) checks to ensure all current and new employees are not listed on the OIG, GSA, or state lists. And, they emphasize anyone who hires an individual or entity on the exclusion list (LEIE) may be subject to civil monetary penalties (CMP).

As shared by Paul S. Weidenfeld, JD at Exclusion Screening, the following are penalties that healthcare entities may face:


Remember, even if your employee has been with you for an extended period, screening should take place.  In the world of healthcare, employees can work at multiple facilities; therefore, you must ensure they were not excluded from the list due to issues with a current employer.

In our opinion, since this process is time-consuming, hiring vendors to complete the screening is your best option. These services, when done right, will give you the peace of mind that all databases are being monitored for over 40 state lists.

But, if you still want to oversee this process manually, you can start by reviewing the OIG’s “Exclusions Program” on their website.

**The opinions and observations from the group/author are not a promise to exempt your practice from fines and penalties.  Research, modify, and tailor the advice to fit your specialty. 

Joi Sherrod, MPH, CPC, CPCO
Joi Sherrod, MPH, CPC, CPCO
Joi is an educator and owner of JNC Healthcare Compliance Group. After working for distinguished academic teaching hospitals and clinics, she is passionate about helping medical, dental, and behavioral health practices rethink healthcare compliance one trend at a time. Contact Joi at