{"what_this_is":"Where the paperwork is — the duties that create the most screening paperwork, ranked, with the official figures that exist. This is the order we build in, printed in public.","method":"Ranked by how much paperwork the rule creates: how often the check recurs × how many people or vendors it touches × how many files each check reads. Official figures are quoted as the source printed them on the read date, with the link. Where no official count exists we either did arithmetic from the rule's cadence and said so, or printed 'not read'. The ranking is our judgement about where the burden sits; it is not a statement about any organisation's compliance.","read_on":"2026-10-02","rows":[{"rank":1,"id":"monthly-workforce-screening","duty":"Monthly exclusion screening of every employee, contractor, FDR and network provider","who":"Hospitals and health systems, Medicare Advantage and Part D sponsors and each of their FDRs, Medicaid managed-care organisations, pharmacy chains, laboratories, staffing and billing companies","big_company_fit":"The largest payers and health systems carry hundreds of thousands of employees and tens of thousands of vendors — every one of them on the monthly list.","recurrence":"monthly, per person and per vendor, against LEIE, SAM and every state Medicaid list","rules":[{"cite":"HHS-OIG Special Advisory Bulletin on the Effect of Exclusion (2013) — monthly screening recommended","url":"https://oig.hhs.gov/exclusions/special-advisory-bulletin-and-other-guidance/the-effect-of-exclusion-from-participation-in-federal-health-care-programs-2013/"},{"cite":"42 CFR 422.503(b)(4)(vi) and 423.504(b)(4)(vi) — MA / Part D compliance program, FDR exclusion checks","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-422/subpart-K/section-422.503"},{"cite":"42 CFR 455.436(c)(2) — LEIE and SAM checked no less frequently than monthly","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.436"}],"figures":[{"figure":"The LEIE is updated monthly; OIG recommends that providers screen employees and contractors monthly","source":"HHS-OIG, Special Advisory Bulletin (2013)","url":"https://oig.hhs.gov/exclusions/special-advisory-bulletin-and-other-guidance/the-effect-of-exclusion-from-participation-in-federal-health-care-programs-2013/","kind":"official"},{"figure":"Civil monetary penalty of up to $10,000 for each item or service furnished by an excluded person, plus an assessment of up to three times the amount claimed","source":"HHS-OIG, Special Advisory Bulletin (2013)","url":"https://oig.hhs.gov/exclusions/special-advisory-bulletin-and-other-guidance/the-effect-of-exclusion-from-participation-in-federal-health-care-programs-2013/","kind":"official"},{"figure":"51 state and territorial Medicaid exclusion jurisdictions mapped; 15 read as files on this platform, the rest named as not read","source":"Alpha Covenant Holdings, Known Limits","url":"https://alphacovenantholdings.com/api/public-record/known-limits","kind":"this platform"}],"arithmetic":"An organisation with 50,000 employees and 5,000 vendors that screens monthly performs 660,000 LEIE look-ups a year, and the same again for SAM and for each state list it reads. Our arithmetic from the rule's cadence — not a published figure.","why_heavy":"Highest recurrence (12× a year) × the largest population a rule touches (everyone on payroll, every vendor) × several files per look-up.","coverage":{"duty_sheets":["oig-cpg-monthly","cms-fdr-oversight","42-cfr-455-436"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/roster"},"build_order":"1 — built: whole-roster batch with a monthly line-by-line diff; roster trial door at /roster"},{"rank":2,"id":"state-medicaid-screening","duty":"State Medicaid agency enrollment screening, monthly database checks and five-year revalidation","who":"State Medicaid agencies and their program-integrity units; by contract, the MCOs that must enrol their network providers with the state","big_company_fit":"A state carries every enrolled provider, owner, agent and managing employee — the largest MCOs carry the same list again for their networks.","recurrence":"at enrollment and revalidation (every 5 years), and monthly for LEIE and SAM","rules":[{"cite":"42 CFR 455.436 — federal database checks","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.436"},{"cite":"42 CFR 455.414 — revalidation of enrollment at least every 5 years","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.414"},{"cite":"42 CFR 438.608(b) — MCO network providers enrolled with the state under Part 455 screening","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-438/subpart-H/section-438.608"}],"figures":[{"figure":"Checks required upon enrollment and revalidation, and no less frequently than monthly for LEIE and SAM","source":"42 CFR 455.436(c)","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.436","kind":"official"},{"figure":"Revalidation of all providers at least every 5 years","source":"42 CFR 455.414","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-455/subpart-E/section-455.414","kind":"official"}],"arithmetic":"A state with 150,000 enrolled providers performs 1.8 million monthly LEIE/SAM reads a year before counting owners, agents and managing employees. Our arithmetic — not a published figure.","why_heavy":"Monthly cadence over an entire state's provider population, with identity confirmation on every row.","coverage":{"duty_sheets":["42-cfr-455-436-state","42-cfr-455-436"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/government"},"build_order":"2 — built: state-agency Duty Sheet, batch; door at /government"},{"rank":3,"id":"credentialing","duty":"Practitioner credentialing and re-credentialing — primary-source verification of sanctions and exclusions","who":"Health plans, CVOs, hospitals' medical-staff offices, delegated credentialing entities and the platforms that serve them","big_company_fit":"National plans and CVOs credential hundreds of thousands of practitioners on a rolling 2–3 year cycle, with monthly sanction monitoring between cycles.","recurrence":"initial, then every 24–36 months; sanction monitoring monthly","rules":[{"cite":"NCQA Credentialing standards — Medicare/Medicaid sanctions verified from an acceptable source within the time frame","url":"https://www.ncqa.org/programs/health-plans/credentialing/"}],"figures":[{"figure":"More than 1.4 million providers maintain profiles in CAQH ProView","source":"CAQH","url":"https://www.caqh.org/hubfs/43908627/drupal/about/marketing/caqh-medicaid-overview.pdf","kind":"published by the file's operator"},{"figure":"8 to 12 hours of staff time per payer application; 3 to 6 hours per re-credentialing","source":"payerready.com (industry estimate)","url":"https://payerready.com/blog/credentialing-cost-per-provider","kind":"industry estimate — not an official figure"}],"arithmetic":"1.4 million practitioners re-credentialed every 3 years is about 467,000 files a year, each with its own sanctions verification and date. Our arithmetic on CAQH's count — not a published figure.","why_heavy":"Large population × multi-hour files × a strict verification-date window that makes the read date itself the evidence.","coverage":{"duty_sheets":["ncqa-cr-sanctions"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/roster"},"build_order":"3 — built: NCQA sanctions Duty Sheet; dated primary-source read on every receipt"},{"rank":4,"id":"federal-prime-subcontracts","duty":"Federal prime contractors — exclusion check before every subcontract over $35,000, plus subaward reporting","who":"Defence, IT, construction and services primes; their subcontract-administration and supplier-diversity offices","big_company_fit":"The largest primes hold tens of thousands of active subcontracts and file subaward reports on each — the check repeats on every award and every option.","recurrence":"per subcontract, before award; subaward report per award over $30,000","rules":[{"cite":"FAR 52.209-6 — check SAM.gov before subcontracts over $35,000","url":"https://www.acquisition.gov/far/52.209-6"},{"cite":"FFATA — subaward and executive-compensation reporting (now in SAM.gov)","url":"https://sam.gov/fsrs"}],"figures":[{"figure":"FFATA subaward reporting: 536,394 subaward responses and 539,500 total annual burden hours","source":"Federal Register, 2024-11437 (May 24, 2024)","url":"https://www.federalregister.gov/documents/2024/05/24/2024-11437/submission-for-omb-review-ffata-subaward-and-executive-compensation-reporting-requirements","kind":"official"},{"figure":"Subcontracting plans (OMB 9000-0007): 49,296 responses, 112,704 annual burden hours","source":"reginfo.gov ICR 202503-9000-006","url":"https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202503-9000-006","kind":"official"}],"arithmetic":"Each of the 536,394 reported subawards is also a FAR 52.209-6 check: roughly half a million dated SAM reads a year across the prime community. Our arithmetic — not a published figure.","why_heavy":"Per-transaction cadence over a very large transaction count, with the record kept in each contract file.","coverage":{"duty_sheets":["far-52-209-6"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/roster"},"build_order":"4 — built: FAR 52.209-6 Duty Sheet, UEI-keyed receipt, batch"},{"rank":5,"id":"grants-and-single-audit","duty":"Grants — covered-transaction check on every subaward and vendor, and the auditor's test of it in the Single Audit","who":"Universities, states, counties, hospitals and nonprofits as pass-through entities; the accounting firms that perform their Single Audits","big_company_fit":"A large university or state agency issues thousands of subawards; the national accounting firms audit the suspension-and-debarment requirement across hundreds of clients a year.","recurrence":"per covered transaction; tested annually in every Single Audit where the requirement is direct and material","rules":[{"cite":"2 CFR 200.214 / 2 CFR 180.300 — verify before a covered transaction","url":"https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I/part-180/subpart-C/section-180.300"},{"cite":"2 CFR 200 Appendix XI, Compliance Supplement, Part 3 §I — Procurement and Suspension and Debarment","url":"https://www.whitehouse.gov/wp-content/uploads/2025/05/2023-Compliance-Supplement-%E2%80%93-2-CFR-Part-200-Appendix-XI.pdf"}],"figures":[{"figure":"Procurement and Suspension and Debarment is one of the twelve compliance requirements the Compliance Supplement subjects to audit","source":"OMB Compliance Supplement, Part 3","url":"https://www.whitehouse.gov/wp-content/uploads/2025/05/2023-Compliance-Supplement-%E2%80%93-2-CFR-Part-200-Appendix-XI.pdf","kind":"official"},{"figure":"Count of Single Audits submitted each year: not read on this platform (FAC publishes the data; we have not loaded it)","source":"Federal Audit Clearinghouse","url":"https://www.fac.gov","kind":"not read"}],"arithmetic":null,"why_heavy":"Two parties carry the same check — the grantee when it transacts and the auditor when it tests — so every dated read is used twice.","coverage":{"duty_sheets":["2-cfr-200-214","single-audit-s-and-d"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/firms"},"build_order":"5 — built: grantee and auditor Duty Sheets; FAC single-audit status on the receipt"},{"rank":6,"id":"medicare-enrollment","duty":"Medicare enrollment and revalidation (CMS-855 family)","who":"Institutional providers (855A), clinics and group practices (855B), physicians (855I) — and the enrollment teams and firms that file for them","big_company_fit":"A multi-state health system files and revalidates for every certified location and every billing practitioner.","recurrence":"initial, changes of information, revalidation every 5 years (3 for DMEPOS)","rules":[{"cite":"42 CFR 424.515 — revalidation","url":"https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-424/subpart-P/section-424.515"}],"figures":[{"figure":"CMS-855A (OMB 0938-0685): 424,092 annual responses, 117,128 annual burden hours","source":"reginfo.gov ICR 202408-0938-001","url":"https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202408-0938-001","kind":"official"},{"figure":"CMS-855B: 108,642 annual responses, 171,885 annual burden hours","source":"reginfo.gov ICR 202105-0938-009","url":"https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202105-0938-009","kind":"official"}],"arithmetic":null,"why_heavy":"The government's own burden estimates put the two forms alone near 290,000 hours a year — and the forms ask for the same ownership, exclusion and licence facts the receipt reads.","coverage":{"duty_sheets":[],"batch_monthly_diff":false,"receipt_watch":false,"door":null},"build_order":"6 — the receipt already prints PECOS enrollment, NPPES and exclusions by NPI; an 855-section Duty Sheet is next"},{"rank":7,"id":"contracting-officer-award","duty":"Contracting officer's exclusion review and responsibility determination before award","who":"Federal contracting officers and contract specialists; the file is the agency's","big_company_fit":"Agency side: millions of actions a year, each with a documented SAM review.","recurrence":"per award, before award and again immediately prior to award","rules":[{"cite":"FAR 9.405(d), 9.104-1, 9.104-6, 9.105-2","url":"https://www.acquisition.gov/far/9.405"}],"figures":[{"figure":"FPDS FY2025 report: 4,120,544 prime contract actions counted for small business concerns","source":"GSA, FPDS report","url":"https://origin-www.gsa.gov/system/files/FPDS%20Report.pdf","kind":"official"}],"arithmetic":null,"why_heavy":"Very large action count; the documentation requirement is explicit (FAR 9.105-2).","coverage":{"duty_sheets":["far-9-405-co"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/government"},"build_order":"7 — built: contracting-officer Duty Sheet with FAPIIS and the SAM entity record"},{"rank":8,"id":"ofac-and-tprm","duty":"OFAC sanctions screening and third-party-risk questionnaires","who":"Banks, insurers, exporters, title and escrow agents; vendor-management teams answering SIG questionnaires","big_company_fit":"Transaction-level at banks; vendor-level at every large enterprise.","recurrence":"per transaction (OFAC); per vendor, annually or at onboarding (TPRM)","rules":[{"cite":"31 CFR Part 501; OFAC Framework for Compliance Commitments","url":"https://ofac.treasury.gov/recent-actions/20190502"},{"cite":"Shared Assessments SIG","url":"https://sharedassessments.org/sig/"}],"figures":[{"figure":"Exact printed-name reads of SDN and the Consolidated Screening List only — no alias or fuzzy screening is performed here","source":"Alpha Covenant Holdings, Methodology","url":"https://alphacovenantholdings.com/methodology","kind":"this platform"}],"arithmetic":null,"why_heavy":"High volume, but the compliance programme needs fuzzy screening we do not perform; the receipt is an exact-name attachment, not the programme.","coverage":{"duty_sheets":["ofac-screening","sig-vendor-evidence"],"batch_monthly_diff":true,"receipt_watch":true,"door":"/roster"},"build_order":"8 — built as an evidence attachment; not a screening programme"}],"what_this_is_not":"Not legal advice, not a compliance assessment of anyone, not a measure of any organisation. The figures belong to the sources named; the arithmetic is ours and is labelled.","checked_at":"2026-10-02T10:35:09.064491+00:00"}