Exclusion checks on file: a monthly screening record for everyone who touches Medicaid work
An exclusion screening log records, month by month, that every owner, manager, driver, dispatcher, biller, and contractor was searched on the OIG's LEIE, SAM.gov, and each state Medicaid exclusion list you bill under, first before they start work and then every month. Each row shows the person, the list, the search date, the result, how any possible match was resolved, and where the saved proof is filed.
On this page
Who belongs on the screening roster
Screen every person whose work Medicaid or Medicare money pays for, directly or indirectly. For a transportation company that is almost everyone. OIG’s bulletin on exclusion points to ambulance drivers and ambulance company dispatchers when it describes transportation jobs an excluded person cannot hold, and it applies the same ban to management and office work tied to program-paid services, billed separately or not. Federal law also requires every state Medicaid plan to have a way of making sure each NEMT provider and each driver it pays is not excluded (42 U.S.C. 1396a(a)(87)).
| Who | Why they go on the roster |
|---|---|
| The company itself | States check enrolled providers against federal exclusion databases at least monthly (42 CFR 455.436); you should know first |
| Owners with 5% or more, officers, directors | OIG may exclude a provider that an excluded person owns 5% or more of, and Pennsylvania stops paying such an entity |
| Managers and office staff | Management and administrative services fall under the ban even when not billed separately |
| Drivers and attendants | Federal NEMT law names drivers; broker credentialing rules cover drivers and attendants |
| Dispatchers and schedulers | OIG’s bulletin uses ambulance company dispatchers as an example |
| Billers, a billing company, a staffing agency | OIG says you keep the risk when a contractor screens for you, so get their proof |
| Volunteers | OIG’s bulletin applies the payment ban regardless of the person’s status, volunteers included |
Add new people before their first shift, not after. The first check belongs in the driver file along with the license and background check.
The template
Part A: Screening roster
List each person once. Keep full Social Security numbers in the personnel file, not in this log.
| Person (legal name) | Other names used (maiden, former, aliases) | Role | Start date | State lists that apply | Pre-hire check date | End date |
|---|---|---|---|---|---|---|
Part B: Monthly check
One row per person per month. Result codes: C clear, P possible match under review, N possible match shown not to be this person, X confirmed excluded.
| Month | Person | LEIE result | SAM.gov result | State list 1 result | State list 2 result | Proof file name | Checked by | Date |
|---|---|---|---|---|---|---|---|---|
Part C: Possible match worksheet
| Field | Entry |
|---|---|
| Person on your roster | |
| List and date searched | |
| Name as it appears on the list | |
| Details on the list record (date of birth, city and state, occupation, exclusion date, exclusion type) | |
| How you compared it (SSN or EIN verify tool, date of birth, license number, call to the agency) | |
| Outcome: not the same person, or confirmed | |
| If confirmed: date removed from all work, and who was told | |
| Decided by and date |
Part D: Monthly sign-off
| Item | Entry |
|---|---|
| People on the roster this month | |
| People checked on every list | |
| New hires checked before their first shift | |
| Possible matches opened and closed | |
| Confirmed exclusions | |
| LEIE update used (month) | |
| Signed by the compliance contact and date |
Running the check each month
Pick a fixed date after the middle of the month. Both LEIE versions are generally refreshed by mid-month and include everything OIG did the month before, so a search on the 20th picks up the latest additions.
- Search the LEIE. The online search takes up to five names at a time. A larger roster can use the downloadable file, but that file has no Social Security or employer numbers, so possible matches still go through the online verify step.
- Search SAM.gov exclusions. SAM holds debarments from many federal agencies, not only OIG. Each record shows the excluding agency, the exclusion type, the date it went active, and a termination date that may read “Indefinite”.
- Search each state list that applies to the person (see the next section).
- Search every name. Include former and maiden names, and search the company and its owners as well as staff.
- Save the proof. OIG advises keeping a record of the initial name search, a printed screenshot for example, and of any later searches used to settle a possible match. Modivcare asks that each saved copy show when the check ran, the driver’s full name, which database was searched and its web address, what the search found, and any outside vendor that ran it.
- Fill in Part B and sign Part D.
State lists to add to your check
OIG recommends checking the exclusion list of every state Medicaid program you take part in, not only your home state. Its own example is a hospital billing Illinois and Iowa Medicaid screening staff against both states’ lists. Rules differ by state:
| State | List | What the state says |
|---|---|---|
| Georgia | Georgia Medicaid Exclusion List (DCH-OIG), updated at least monthly | Providers must search it, the LEIE, and SAM every month and before hiring, and report any exclusion found among staff to DCH provider enrollment immediately |
| Pennsylvania | Medicheck List, updated daily | Screen all employees and contractors at hire and monthly; a possible match can be checked with the last four digits of the SSN or the entity’s FEIN |
| Texas | Texas Exclusions List (HHS OIG) | Providers should check it monthly and notify OIG if a current employee is excluded |
| Illinois | Provider Sanctions list (HFS OIG) | The department may recoup treble damages and fines of up to $10,000 per claim for services billed while a vendor employs sanctioned providers |
| New York | NYS Medicaid Exclusion List (OMIG) | Search up to five names at once; a separate short list shows exclusions from the last 30 days |
| Washington | Provider termination and exclusion list (HCA) | Lists providers terminated for cause and providers excluded under federal rules |
Your broker may name the lists for you. Modivcare’s reminder to out-of-network providers calls for OIG, SAM, and any applicable state exclusion database at hire and monthly, and says it audits a sample of those providers each quarter.
When a name matches
A name match is a question, not an answer, so settle it before acting on it.
- Compare the record. Check date of birth, city, and occupation on the list record against your file. On the LEIE, click verify and enter the Social Security number (or the company’s EIN). Pennsylvania’s Medicheck verify link takes the last four digits of the SSN.
- Close it or confirm it within the day. Record the outcome in Part C. Keep a confirmed person off every task federal health care money pays for until it is settled.
- Work out what was billed. OIG treats payment for services an excluded person furnished as an overpayment, whether or not that person billed anything. Overpayments come with a return deadline, covered in our guide to the 60-day overpayment rule.
- Consider self-disclosure. OIG points employers who find an excluded person to its Self-Disclosure Protocol. Before disclosing, you must screen every current employee and contractor against the LEIE, and the disclosure describes the person’s duties and dates, your screening process, the gap that let them through, and the fix.
- Report to the state where required. Georgia and Texas both ask to be told.
The cost of skipping the check is high. The penalty rule sets a ceiling of $20,000 per item or service an excluded person furnished; after HHS’s inflation adjustment, penalties assessed from January 28, 2026 can reach $25,595. On top of that, OIG may assess triple the amount claimed or, for work not billed separately, triple the company’s costs for that person, including salary, benefits, and taxes (42 CFR 1003.210). Self-disclosed matters that do not involve kickbacks settle for at least $20,000.
An OIG exclusion ends only with reinstatement. OIG removes a person from the LEIE after it grants reinstatement in writing, and simply getting a new provider number does not count.
Keeping the log audit-ready
Keep the log and the saved results together, month by month, where only the people who run screening can see them. Brokers check this file during credentialing reviews and audits, as our guide to passing a NEMT broker audit explains. Exclusion checks are one recurring date among many, so put yours on the NEMT compliance calendar and give one person ownership, usually the compliance contact described in our NEMT compliance program guide.
Making the monthly check hard to miss
HealthRide can hold the monthly exclusion check as a driver credential with a one-month expiration date, alongside the license and training records. A reminder goes out before it runs out, and an expired check shows as a warning before that driver is assigned a trip. The fleet and credentials page explains how tracking works.
Frequently asked questions
- Is monthly exclusion screening a legal requirement for NEMT providers?
- It depends on who you answer to. OIG's own bulletin says no law or rule obliges providers to search the LEIE, yet it advises a monthly search because the list is updated every month. Several states and brokers go further: Georgia and Pennsylvania Medicaid tell providers to screen employees and contractors before hire and every month, and Modivcare's instructions to out-of-network providers call for a driver check at hire and monthly after. Federal law also makes each state have a way to ensure that the NEMT providers and drivers it pays are not excluded.
- Do office staff need exclusion checks, or only drivers?
- Office staff too. OIG's 2013 bulletin on the effect of exclusion bars excluded people from transportation work that federal health care programs pay for. Its examples are ambulance drivers and ambulance company dispatchers. It also bars them from management and office jobs connected to that work, such as office management, billing and accounting, or staff training, even when the job is never billed as a separate service.
- How does the LEIE differ from SAM.gov exclusion records?
- They draw from different agencies. Only OIG's own exclusions appear on the LEIE. SAM.gov, which the General Services Administration maintains, collects debarment actions from many federal agencies, and OIG exclusions show up there too. OIG tells providers to treat the LEIE as the main source for its exclusions, since each record carries more: the statutory basis, the person's occupation at the time, and date of birth. When a broker or state names both lists, run both searches.
- What steps follow when a current driver turns out to be excluded?
- Take the driver off every trip and task that federal health care money pays for the same day, then work out what was billed. Payments for services an excluded person furnished are overpayments. OIG suggests weighing its Self-Disclosure Protocol, which first requires screening all current staff and contractors against the LEIE. Some states want to hear right away: Georgia tells providers to report any exclusion found among staff to its provider enrollment section immediately.
- How long should screening records be kept?
- Match the longest retention period among your contracts. Modivcare sets a 10-year retention period for the driver credentialing files of out-of-network providers, exclusion checks included, and expects them within 3 business days when asked. Store each month's saved results with the log so an auditor can tie every proof to its row.
- Can a third-party screening service do the checks for us?
- Yes, although the liability does not move to the vendor. Under OIG's bulletin, a provider that leaves screening to a contractor still faces overpayment and penalty exposure if an excluded person gets through, so get the vendor's reports every month and file them here. Modivcare also wants the vendor named on each saved result.
