Alpha Covenant Holdings · Burden Board · read 2026-10-02 · site view · JSON
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.
Who carries it: 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 · Recurrence: monthly, per person and per vendor, against LEIE, SAM and every state Medicaid list
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.
The rules:
Official figures as read 2026-10-02:
Our 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 it ranks here: Highest recurrence (12× a year) × the largest population a rule touches (everyone on payroll, every vendor) × several files per look-up.
Build order: 1 — built: whole-roster batch with a monthly line-by-line diff; roster trial door at /roster
Who carries it: State Medicaid agencies and their program-integrity units; by contract, the MCOs that must enrol their network providers with the state · Recurrence: at enrollment and revalidation (every 5 years), and monthly for LEIE and SAM
A state carries every enrolled provider, owner, agent and managing employee — the largest MCOs carry the same list again for their networks.
The rules:
Official figures as read 2026-10-02:
Our 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 it ranks here: Monthly cadence over an entire state's provider population, with identity confirmation on every row.
Build order: 2 — built: state-agency Duty Sheet, batch; door at /government
Who carries it: Health plans, CVOs, hospitals' medical-staff offices, delegated credentialing entities and the platforms that serve them · Recurrence: initial, then every 24–36 months; sanction monitoring monthly
National plans and CVOs credential hundreds of thousands of practitioners on a rolling 2–3 year cycle, with monthly sanction monitoring between cycles.
The rules:
Official figures as read 2026-10-02:
Our 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 it ranks here: Large population × multi-hour files × a strict verification-date window that makes the read date itself the evidence.
Build order: 3 — built: NCQA sanctions Duty Sheet; dated primary-source read on every receipt
Who carries it: Defence, IT, construction and services primes; their subcontract-administration and supplier-diversity offices · Recurrence: per subcontract, before award; subaward report per award over $30,000
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.
The rules:
Official figures as read 2026-10-02:
Our 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 it ranks here: Per-transaction cadence over a very large transaction count, with the record kept in each contract file.
Build order: 4 — built: FAR 52.209-6 Duty Sheet, UEI-keyed receipt, batch
Who carries it: Universities, states, counties, hospitals and nonprofits as pass-through entities; the accounting firms that perform their Single Audits · Recurrence: per covered transaction; tested annually in every Single Audit where the requirement is direct and material
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.
The rules:
Official figures as read 2026-10-02:
Why it ranks here: Two parties carry the same check — the grantee when it transacts and the auditor when it tests — so every dated read is used twice.
Build order: 5 — built: grantee and auditor Duty Sheets; FAC single-audit status on the receipt
Who carries it: Institutional providers (855A), clinics and group practices (855B), physicians (855I) — and the enrollment teams and firms that file for them · Recurrence: initial, changes of information, revalidation every 5 years (3 for DMEPOS)
A multi-state health system files and revalidates for every certified location and every billing practitioner.
The rules:
Official figures as read 2026-10-02:
Why it ranks here: 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.
Build order: 6 — the receipt already prints PECOS enrollment, NPPES and exclusions by NPI; an 855-section Duty Sheet is next
Who carries it: Federal contracting officers and contract specialists; the file is the agency's · Recurrence: per award, before award and again immediately prior to award
Agency side: millions of actions a year, each with a documented SAM review.
The rules:
Official figures as read 2026-10-02:
Why it ranks here: Very large action count; the documentation requirement is explicit (FAR 9.105-2).
Build order: 7 — built: contracting-officer Duty Sheet with FAPIIS and the SAM entity record
Who carries it: Banks, insurers, exporters, title and escrow agents; vendor-management teams answering SIG questionnaires · Recurrence: per transaction (OFAC); per vendor, annually or at onboarding (TPRM)
Transaction-level at banks; vendor-level at every large enterprise.
The rules:
Official figures as read 2026-10-02:
Why it ranks here: High volume, but the compliance programme needs fuzzy screening we do not perform; the receipt is an exact-name attachment, not the programme.
Build order: 8 — built as an evidence attachment; not a screening programme
Not legal advice, not a compliance assessment of anyone. Figures belong to the sources named; the arithmetic is ours and is labelled.