OIG and SAM Exclusion Checks

The Hidden Compliance Risk Providers Overlook

When healthcare providers think about background checks, they often focus on criminal records, employment verification, and professional licenses. These are all critical, but they’re not enough. One of the most overlooked yet high-risk areas in healthcare hiring and compliance is screening for federal exclusions. Specifically, every provider must conduct OIG exclusion checks and SAM exclusion checks to remain compliant and protect their revenue streams.

Failure to do so isn’t a minor oversight. It can trigger massive recoupments, loss of payer contracts, civil fines, and even criminal penalties. Yet many healthcare employers still treat these checks as optional; or worse, assume their generic background screening vendor is already doing them.

What Is an OIG Exclusion Check?

The Office of Inspector General (OIG) maintains a federal database called the List of Excluded Individuals and Entities (LEIE). If a person or company is on this list, they are banned from participating in federally funded healthcare programs such as Medicare and Medicaid.

Healthcare employers are prohibited from hiring, contracting with, or billing services from individuals or entities on this list. This applies to:

  • Physicians, nurses, therapists, and other licensed professionals.

  • Administrative staff in billing, coding, or compliance roles.

  • Contractors and vendors who provide patient care or administrative services.

What Is a SAM Exclusion Check?

The System for Award Management (SAM) database is broader in scope. It includes individuals and organizations that are excluded, debarred, or otherwise prohibited from federal contracts and assistance programs.

While OIG exclusions focus on healthcare, SAM exclusions apply across all federal contracting activities, which means hospitals, behavioral health facilities, and community clinics receiving federal grants or reimbursements must ensure no excluded parties are in their workforce or vendor network.

Why Overlooking OIG and SAM Checks Is a Serious Compliance Risk

Many providers assume that a standard criminal background check is enough. It isn’t. Exclusions are regulatory determinations, not criminal convictions, and often don’t appear in criminal record databases.

The risks of skipping exclusion checks are enormous:

  • Civil monetary penalties: Providers may owe back every dollar billed for services delivered by an excluded individual.

  • Loss of payer contracts: Insurers and government payers can terminate agreements if excluded staff are discovered.

  • Accreditation jeopardy: Joint Commission and CARF surveyors increasingly review HR files for exclusion screening.

  • Reputation damage: Being flagged for employing an excluded individual can make headlines and erode patient trust.

Exclusion checks need to be systematic, ongoing, and documented. Best practices include:

  • Screening every applicant during pre-hire checks.

  • Running OIG and SAM searches monthly or quarterly to capture new exclusions.

  • Documenting results in HR files to show regulators and auditors.

  • Extending checks to contractors, vendors, and temporary staff.

Generic CRA vendors often miss these steps or run them inconsistently. A healthcare-focused CRA like Auradon Solutions integrates exclusion checks directly into the background screening workflow, ensuring compliance every time.

The Auradon Advantage: Protecting Providers from Hidden Risks

Auradon Solutions is built for healthcare. Our background screening process includes OIG and SAM exclusion checks as standard—not as add-ons. We combine this with license verification, abuse and neglect registry searches, and occupational health screenings, creating a comprehensive compliance shield for providers.

Healthcare compliance isn’t just about onboarding faster; it’s about protecting patients, revenue, and reputation. That’s why Auradon Solutions is the background check company for healthcare.

Ready to protect your workforce and your bottom line? Get started with Auradon Solutions now to customize your background screening process.

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