What is a SAM exclusion check, and how is it different from the LEIE?
A SAM exclusion check means looking up a person or company in the exclusion records on SAM.gov, the federal System for Award Management that GSA operates. SAM lists people and companies debarred or suspended by any federal agency, HHS OIG included, while the LEIE lists only OIG exclusions. States must check it at least monthly, and MTM's standard contract bars drivers who appear on federal exclusion lists.
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Two federal lists, two jobs
SAM and the LEIE overlap but are not the same list. HHS OIG’s exclusions FAQ explains the difference: SAM, administered by the General Services Administration, contains debarment actions by many federal agencies, including OIG’s exclusions, while the LEIE contains only OIG’s.
| List | Kept by | What it holds | Why a NEMT company cares |
|---|---|---|---|
| LEIE | HHS Office of Inspector General | People and companies OIG has barred from federal health care programs | No Medicare or Medicaid payment for anything they furnish |
| SAM.gov exclusions | General Services Administration | Debarments, suspensions, and other exclusions from any federal agency, OIG included | Named in Medicaid screening rules, managed care rules, and broker contracts |
| State exclusion list | The state Medicaid agency or its inspector general | People and companies the state has barred | State manuals and contracts can require it alongside the federal lists |
The two carry different effects. OIG says its health care exclusions do not by themselves reach other federal programs, though another agency can separately debar the same person. Medicaid managed care rules add their own bar on debarred parties, as the next section shows.
Older documents still call the SAM data the Excluded Parties List System, or EPLS. The federal screening rule for states names the LEIE and EPLS, and MTM’s standard agreement uses the EPLS name too. SAM records created before August 2012 can still carry the old EPLS cause and treatment codes.
Who has to check SAM
- State Medicaid agencies confirm identity and check exclusion status for every provider and for anyone with an ownership or control interest, agent, or managing employee, searching the LEIE and EPLS at least monthly (42 CFR 455.436).
- Medicaid health plans may not knowingly have a director, officer, partner, 5 percent owner, subcontractor, or network provider who is debarred under federal procurement or nonprocurement rules (42 CFR 438.610). Federal rules apply that ban to NEMT-only brokers paid on a prepaid basis as well (42 CFR 438.9(b)(9)).
- Brokers by contract. Louisiana’s Medicaid manual has the broker search the LEIE, the Louisiana Adverse Actions List, and SAM every month, report any exclusion to the state within three business days, and return payments for services by an excluded provider within 30 days of discovery. MTM’s standard agreement bars any driver or attendant on the OIG list, the EPLS, or similar government exclusion lists, and wants immediate notice if an owner, officer, director, or manager is barred.
In practice, a transportation company screens its owners and managing employees, every driver and attendant, office staff, and any company it sends trips to.
Running and recording the search
- Search by name on SAM.gov’s exclusion search, including former names and aliases. SAM records carry a cross-reference field for other names a person or firm has used.
- Read the record. Each one shows a classification (individual, firm, special entity designation, or vessel), the excluding agency, an exclusion type, an active date, and a termination date that may read “Indefinite.”
- Know the four exclusion types. Ineligible (Proceedings Pending), Ineligible (Proceedings Completed), Prohibition/Restriction, and Voluntary Exclusion. For the last two, SAM points you to the record’s comments or the excluding agency for the terms.
- Confirm before acting. A name match is not a confirmed match. For an OIG exclusion, OIG’s online LEIE search can check an individual against a Social Security number or a company against an employer ID number. For another agency’s action, contact that agency.
- Keep proof. Record who searched, the date, each name, each list, and the result, in a log such as the exclusion screening log or the driver file checklist.
Federal nonprocurement rules accept three ways to check a lower-tier partner: searching SAM.gov exclusions, collecting a certification, or adding a clause to the contract (2 CFR 180.300). Certifications and contract clauses depend on the other party to speak up. A repeated search does not.
Where software fits
Exclusion searches run on SAM.gov, the LEIE, and state sites. HealthRide tracks each driver’s other credentials and expiration dates in one fleet and credentials registry, with reminders before a date lapses and a flag when someone with an expired credential is assigned a trip.
Frequently asked questions
- If I already search the LEIE every month, do I still need SAM?
- Yes. The LEIE holds only exclusions imposed by the HHS Inspector General. SAM also carries debarments and suspensions from every other federal agency. Federal Medicaid rules, managed care rules, and broker contracts name both lists, so a screening program that stops at the LEIE leaves a gap.
- How often do SAM searches need to happen?
- Monthly, and before anyone new starts. State Medicaid agencies must check the federal exclusion databases at least once a month, and Louisiana has its broker search SAM, the LEIE, and the state adverse actions list monthly to catch new exclusions and reinstatements. Matching that pace keeps your records in step with the payer's.
- What does "Indefinite" mean on a SAM record?
- It means the exclusion has no set end date. For the "Ineligible (Proceedings Pending)" type, SAM shows the termination date as indefinite unless another date is given, because the person stays ineligible until the investigation or legal proceedings finish. Treat the record as active until SAM shows it ended.
- Someone is excluded by a non-health agency. Can they still drive Medicaid trips?
- Assume not. Health plans and NEMT-only brokers paid on a prepaid basis may not knowingly keep network providers, subcontractors, or staff and consultants whose work is significant and material to the contract, if they are debarred under federal procurement or nonprocurement rules. Broker contracts close the rest of the gap: MTM's standard agreement bars any driver or attendant listed on the OIG list, the federal excluded parties list, or similar government exclusion lists.
