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As a Medicaid-enrolled provider, the practice checks every employee and contractor against two federal exclusion databases at hire and at least monthly afterward. An excluded person cannot be paid, directly or indirectly, with federal healthcare program money. The practice is enrolling with Utah Medicaid and isn’t submitting claims yet; the screening obligation attaches to enrollment, so we do it now.

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The two databases

  • OIG LEIE (List of Excluded Individuals and Entities), maintained by the HHS Office of Inspector General.
  • SAM.gov exclusions, maintained by the General Services Administration.
Both are free and take a few minutes to search.

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When we check

The practice manager owns the monthly check and keeps a dated record of each run: date, names checked, result, and who ran it. The record is the compliance artifact. A check that isn’t documented didn’t happen.

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What we need from you

  • Tell us immediately if you are, or become, excluded, debarred, or under investigation by any federal or state healthcare program.
  • Confirm at hire that you are not excluded. This is part of your acknowledgment.

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If a match comes up

Most matches are name coincidences. The practice manager confirms identity with date of birth and other identifiers before taking any action. If a match is confirmed, Helen is notified the same day and the person is removed from any work touching federal program services until it’s resolved.
Why. Paying an excluded person with Medicaid money creates real liability for the practice, including repayment and civil penalties (42 U.S.C. § 1320a-7a(a)(6)). The check is two minutes a month. Where the duty comes from: the Utah Medicaid Provider Manual, Section I, requires providers to check the OIG list monthly; the HHS Office of Inspector General’s 2013 Special Advisory Bulletin recommends the same; and 42 CFR § 455.436 requires the state Medicaid agency to screen enrolled providers, owners, and managing employees at enrollment and monthly.