Alpha Covenant Holdings · Duty Sheet · generated 2026-10-02 09:46 UTC · free · all sheets

Counsel — exclusion, debarment and enforcement evidence for transaction diligence and compliance programmes

Applies to: Law firms advising on health-care and government-contracts transactions, compliance programme reviews, and responses to agencies · Rule text: https://oig.hhs.gov/exclusions/special-advisory-bulletin-and-other-guidance/the-effect-of-exclusion-from-participation-in-federal-health-care-programs-2013/

The question the rule asks

On the date of the read, was the target, its owners, managing employees or key vendors excluded (OIG LEIE, state lists), debarred or suspended (SAM), under a corporate integrity agreement, sanctioned (OFAC), or named in a public enforcement record? The OIG bulletin describes the civil-monetary-penalty exposure that follows from excluded persons.

The party this sheet is about

Wellpath LLC · keys supplied: UEI JL99G1YPJKK9 · matching: screening-2026-06f: every check is an exact-name (or exact-UEI / exact-NPI / exact-EIN / exact-CIK) lookup against the official file named on the line; nothing is inferred from similar names, owners or affiliates

Receipt r_31d32d5ac3884154 · read 2026-10-02 09:46:12 UTC · SHA-256 0764aca8842c0e0d7d104e541fa4028348b503ddaa63f978027bf620d0dd83bd · verify: https://alphacovenantholdings.com/r/r_31d32d5ac3884154

The official files that answer it, as read on that date

SourceRoleStateRecordsWhat it printed
HHS Office of Inspector General — LEIE (monthly downloadable file)answers the questionanswered0No entry under this exact name in the OIG file fetched 2026-09-27.
SAM.gov Exclusions — Public Extract V2 (GSA, daily)answers the questionanswered0No entry under this exact name/UEI in the SAM extract fetched 2026-10-01 (SAM_Exclusions_Public_Extract_V2_26274.ZIP).
State Medicaid exclusion / termination lists (each state's own published file)answers the questionanswered0No entry under this exact name/NPI in the 15 state lists read (latest fetch 2026-10-01); 29 state lists are published in forms we cannot read and were not checked.
HHS-OIG Corporate Integrity Agreements (public browse list, exact printed party name)supportinganswered0No corporate integrity agreement under this exact printed party name.
U.S. Treasury OFAC — Specially Designated Nationals and Blocked Persons List (SDN.CSV)supportinganswered0No entry under this exact name or listed alias on the SDN list fetched 2026-10-01.
Consolidated Screening List (trade.gov) — BIS, State and Treasury lists, OFAC SDN excluded here because it is read directlysupportinganswered00 export-control or sanctions list entries (BIS, State, Treasury non-SDN) under this exact printed name
DEA registrant actions — Decision and Order notices (Federal Register, exact printed party name)supportinganswered0No DEA Decision and Order notice under this exact printed party name.
FDA Debarment List — drug product applications (21 U.S.C. 335a)supportinganswered00 FDA debarment entries (firms) under this exact printed name
SEC EDGAR (registrant submissions index, data.sec.gov)supportinganswered0EDGAR's entity index lists no registrant under this exact printed name (a registrant may file under a different printed name — see the EDGAR company search).
Federal Audit Clearinghouse (GSA) — single audit filings under 2 CFR 200 Subpart FsupportingansweredNo single-audit filing is on file for this exact UEI. Entities below the federal-spending threshold do not file; this is not a finding.

What to record in the file

Each source's file date and read time, the keys used, and the SHA-256 — so the diligence file shows what the public record said on the date counsel read it. For evidence that may be filed, the Litigation Report adds the FRE 902(13) system declaration. Identity of same-name rows is for counsel to resolve.

What this sheet does not decide

The receipt does not decide eligibility, responsibility, identity or compliance. It records what each official file printed for an exact key or exact printed name on a date. A same-name row is a candidate to be resolved by the reader, not a match. Answering the form's question is the applicant's or reviewer's act; this sheet puts the dated record beside it.

Full receipt (all sources, known limits, print record): screening record · Methodology: https://alphacovenantholdings.com/methodology · Corrections (free, public log): https://alphacovenantholdings.com/corrections