How Healthcare Organizations Can Strengthen Compliance Screening
Healthcare compliance teams manage a wide range of responsibilities. They may oversee employee screening, contractor onboarding, physician credentialing, vendor due diligence, documentation, audits, and ongoing monitoring.
One area that deserves consistent attention is exclusion and sanction screening.
The Exclusions List OIG, commonly referring to the HHS-OIG List of Excluded Individuals/Entities (LEIE), is an important federal resource for healthcare organizations.
OIG maintains the LEIE to identify individuals and entities currently excluded from participation in federally funded healthcare programs.
Understanding how this list works—and how it fits into a larger compliance program—can help organizations create more effective screening processes.
What Is the OIG Exclusion List?
The LEIE is maintained by the U.S. Department of Health and Human Services Office of Inspector General.
An exclusion means that an individual or entity has been barred from participation in federally funded healthcare programs under applicable federal authority.
OIG identifies both mandatory and permissive exclusion authorities. Exclusions may result from different circumstances, including certain criminal convictions, licensing-related issues, or other grounds established under federal law.
For healthcare organizations, the important issue is not simply knowing that the database exists.
Organizations need to know how to use it as part of an organized compliance process.
Who Should Healthcare Organizations Screen?
The appropriate screening population will depend on an organization's compliance policies and risk assessment.
Potential populations may include:
Employees
Physicians
Nurses and other healthcare professionals
Contractors
Temporary workers
Vendors
Suppliers
Consultants
Billing companies
Staffing organizations
Other third parties
Organizations should define their screening requirements clearly so that departments understand who needs to be screened and when.
Why Screening Should Be Ongoing
A common compliance mistake is treating screening as a one-time onboarding activity.
A person may not be excluded when they begin working for an organization but could appear on an exclusion list later.
OIG updates the LEIE monthly and discusses routine and periodic screening of employees and contractors. This makes ongoing monitoring an important consideration for healthcare organizations.
Recurring screening can help organizations identify changes in status sooner and maintain better visibility across their workforce.
Understanding Sanction Checks
Healthcare compliance can involve more than federal exclusion screening.
Sanction Checks may involve reviewing multiple sources depending on the organization's business activities, workforce, location, and risk profile.
Potential sources can include:
Federal exclusion information
State exclusion lists
Professional licensing records
Disciplinary information
Other regulatory databases
Organization-specific compliance sources
The exact combination should be determined by the organization's compliance requirements.
A broader screening strategy can help organizations avoid relying too heavily on a single database.
Potential Matches Need Human Review
One of the most important concepts in screening is that a database hit is not necessarily a confirmed match.
Names can be similar or identical.
For example, a healthcare organization may screen an employee named John Smith and find several records with the same name. That does not automatically establish that the employee is the person listed in the database.
Additional information may need to be reviewed.
Depending on the source, organizations may compare:
Name
Date of birth
Address
NPI
License information
Employer
Entity details
Other identifiers
The objective is to determine whether the record actually relates to the person or entity being screened.
How to Document Screening Results
Documentation gives compliance teams a clear record of what happened.
A well-organized record may capture:
The individual or entity screened
Screening date
Source searched
Search result
Potential match details
Review performed
Final determination
Escalation or action taken, if applicable
The exact documentation process will vary by organization.
However, maintaining an appropriate audit trail can make internal reviews and compliance investigations more manageable.
Understanding CMS Open Payments
The CMS Open Payments program has a different purpose from exclusion and sanction databases.
CMS describes Open Payments as a national disclosure program that promotes transparency around certain financial relationships in healthcare.
The program provides public information about payments and transfers of value made by applicable manufacturers and group purchasing organizations to covered recipients.
Covered recipients can include physicians, certain non-physician practitioners, and teaching hospitals.
The important distinction is that Open Payments is a transparency program, not an exclusion database.
Healthcare organizations should therefore avoid treating an Open Payments record as proof that a person or company has violated a regulation.
Instead, the information can provide additional context when organizations are evaluating financial relationships and transparency.
Creating a Stronger Compliance Process
A practical compliance process can be organized around a few key stages.
Identify
Determine which employees, contractors, vendors, and other parties require screening.
Screen
Search applicable federal, state, licensing, and sanction sources.
Investigate
Review potential matches and compare identifying information.
Document
Maintain appropriate records of searches and decisions.
Escalate
Route confirmed concerns to the appropriate internal team.
Monitor
Continue screening according to established organizational requirements.
This structure helps transform compliance screening from an occasional task into a repeatable business process.
Using Technology to Reduce Administrative Work
Manual screening can consume considerable time when an organization has a large population.
Compliance professionals may have to download lists, search names, update spreadsheets, send reminders, and maintain records.
Technology can streamline many of these administrative activities.
For example, automated workflows can help organizations schedule recurring screening, manage populations, organize results, and maintain centralized records.
The objective should be efficiency without sacrificing review quality.
Automation can perform repetitive tasks, while compliance professionals remain responsible for evaluating potential matches and determining appropriate actions.
Frequently Asked Questions
1. What is the Exclusions List OIG?
It generally refers to the HHS-OIG List of Excluded Individuals/Entities, or LEIE, which identifies individuals and entities currently excluded from federally funded healthcare programs.
2. What are Sanction Checks?
Sanction Checks are screening activities that may involve reviewing relevant federal, state, licensing, disciplinary, exclusion, and other regulatory sources based on an organization's requirements.
3. What does CMS Open Payments show?
CMS Open Payments provides publicly available information about certain payments and transfers of value involving applicable reporting entities and covered recipients.
Conclusion
Healthcare compliance works best when organizations use structured and repeatable processes.
The Exclusions List OIG provides an important federal source for identifying excluded individuals and entities. Sanction Checks can broaden screening beyond a single exclusion database, while CMS Open Payments provides a separate source of healthcare financial transparency.
These resources should be used for their intended purposes and supported by accurate information, human review, documentation, and appropriate recurring monitoring.
A thoughtful combination of people, processes, and technology can help healthcare organizations manage compliance activities more efficiently while maintaining a stronger record of their screening efforts.
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