◆ Alpha CovenantPull a Record

HHS-OIG General Compliance Program Guidance (November 2023), Section on exclusion screening; OIG Special Advisory Bulletin on the Effect of Exclusion (2013)

OIG General Compliance Program Guidance: exclusion screening at hire and monthly

OIG recommends screening employees and contractors against the LEIE prior to engagement and periodically thereafter — monthly screening is recommended — and documenting the screening so that it can be shown to have occurred. source

Who it reaches

Every health care entity that bills federal health care programs: hospitals, health systems, practices, SNFs, home health, DME, pharmacies, FQHCs, and their vendors and staffing agencies.

The record the rule expects

One dated record per name per month showing the LEIE file date, the SAM read, the state lists read, the exact match method, the rows printed, and any source that did not answer; the identity decision on any same-name row, recorded separately by your reviewer.

Questions readers ask

What does OIG mean by 'documenting'?

That you can show an auditor the screen occurred: who was screened, against what file version, on what date, with what result. A dated receipt with the file date and a hash is one way to keep that.

Is a name match a finding?

No. OIG's own guidance describes verifying a potential match against the LEIE record's identifiers. A printed-name row is a candidate for your reviewer.

This page quotes the rule and describes the record; whether your organization meets the rule is your compliance office's and counsel's reading. All rules · Methodology.

No tracking cookies; we count visits ourselves, in aggregate. Policy.