The 7 Most Common Healthcare Sanction & Exclusion Screening Lists
Every healthcare compliance team understands that sanction screening is important and exclusion lists must be regularly checked. But which lists should they be focused on – and how can they check them all regularly to maintain compliance?
Healthcare sanction and exclusion screening lists are federal and state databases that identify individuals and entities barred from participating in government-funded healthcare programs, holding professional licenses, or receiving federal contracts, most often due to fraud, patient abuse, or licensing violations. Healthcare organizations screen employees, contractors, and vendors against these lists, most commonly on a monthly cycle, to avoid billing federal programs for services connected to an excluded individual and to identify sanctioned providers before they reach a patient.
This article explores the most important exclusion lists for healthcare organizations in the United States. We explore the challenges and solutions compliance leaders face with these lists – and reveal how automated tools can simplify and scale your sanction screening program.
The 7 Most Common U.S. Healthcare Sanction Lists
Healthcare organizations must conduct sanction screenings using multiple databases to ensure compliance with federal and state regulations
1. Office of Inspector General’s List of Excluded Individuals and Entities (OIG LEIE)
What is it?
The OIG LEIE is a federal database that identifies individuals and entities that have been excluded from participating in federally funded healthcare programs such as Medicare and Medicaid. The database is maintained by the U.S. Department of Health and Human Services (HHS) and can be easily searched via an online portal.
Why is it important?
Most OIG exclusions are imposed due to serious offenses – from healthcare fraud to patient abuse. Regular OIG compliance checks are therefore vital to avoid:
- Financial Losses: The OIG can enforce steep penalties for non-compliance. Organizations can also be stripped of their Medicare reimbursements and made ineligible for future payments.
- Patient Harm: Excluded individuals and entities present a serious risk to patient safety, often due to past misconduct or negligence. Allowing them to engage in patient care can directly compromise the quality, integrity, and safety of that care.
- Reputational Harm: Working with excluded parties can significantly harm your reputation, leading to patient churn and staff recruitment issues.
A monthly LEIE check is the standard, but on its own it can still miss risk that only surfaces between checks. See why monthly OIG LEIE checks fall short.
2. General Services Administration’s System for Award Management (SAM)
What is it?
The U.S. General Service Administration’s SAM is a federal database that tracks individuals and organizations that are prohibited from receiving government contracts. While SAM is not exclusively healthcare-focused, it includes exclusions that can impact healthcare organizations, particularly those working with federal agencies or receiving government funding.
Why is it important?
Like the OIG LEIE, most SAM exclusions are the result of serious misconduct, ranging from criminal convictions to unethical business practices. Rather than direct fines, working with excluded individuals may result in lost government contracts, civil action, or criminal charges.
3. State Medicaid Exclusion Lists
What are they?
State Medicaid exclusion lists are databases maintained by individual states that identify healthcare providers and organizations that have been barred from participating in state-funded healthcare programs. These function similarly to the OIG LEIE but are localized and may differ from the nationwide list kept by the OIG.
Why are they important?
Many individuals or entities are not included within the OIG LEIE – but are excluded at the state level. The same penalties can result from working with these parties, making additional state exclusion list checks essential for full compliance.
Every state that administers Medicaid maintains its own exclusion list, separate from the federal OIG LEIE, and a provider excluded at the state level does not always appear on the federal one, particularly when the underlying conduct falls under a state’s own Medicaid fraud statute rather than federal healthcare fraud law. California’s Medi-Cal Suspended and Ineligible Provider List and New York’s Restricted, Terminated, and Excluded Individuals or Entities list are two of the more frequently referenced examples. Organizations operating across multiple states need a process that checks every state list where they have patients, employees, or contracted providers, not just the state where they are headquartered.
4. National Practitioner Data Bank (NPDB)
What is it?
The National Practitioner Data Bank (NPDB) is a federal database managed by the U.S. Department of Health and Human Services (HHS) that tracks malpractice claims, disciplinary actions, and medical license restrictions against healthcare providers. While not an exclusion list, it serves as a valuable tool for identifying providers with histories of professional misconduct.
Why is it important?
Screening the NPDB allows healthcare organizations to detect problematic providers before they are hired, reducing liability and maintaining high standards of care. Many organizations integrate NPDB screening into their hiring and credentialing processes to safeguard against professional misconduct and protect patients from potentially unqualified practitioners.
5. DEA Controlled Substances Act Registration Exclusions
What is it?
The DEA Controlled Substances Act Registration Exclusions list highlights healthcare providers who have lost their registration to prescribe or dispense controlled substances.
Why is it important?
DEA exclusions can occur due to violations such as illegal prescribing practices, drug-related criminal offenses, or regulatory non-compliance. Engaging with providers who have lost their authority to handle controlled substances can lead to legal penalties, reputational damage, and potential risks to patient safety.
6. World Bank and OFAC Sanctions Lists
What is it?
The World Bank and the U.S. Office of Foreign Assets Control (OFAC) maintain separate sanction lists that impact healthcare organizations operating internationally. The OFAC list includes individuals and entities involved in illegal activities such as fraud, money laundering, or terrorism, while the World Bank Debarred List restricts funding to organizations implicated in corruption or fraudulent activities related to global healthcare projects.
Why is it important?
International operations create a lot of compliance risk, especially for healthcare organizations that often have large and highly complex vendor networks. Screening these international lists is essential to ensure you do not engage with entities involved in illicit activities – and failure to do so can lead to legal action, financial penalties, and reputational harm.
7. Professional Licensing Boards & Medical Boards
What are they?
Professional Licensing Boards and Medical Boards maintain records of healthcare professionals who have had their licenses revoked, suspended, or restricted due to misconduct or violations of professional standards. Each state has its own licensing board, which governs the licensure and disciplinary actions of healthcare providers.
Why are they important?
Ensuring that all employees, contractors, and vendors hold valid professional credentials is essential for compliance and patient safety. Licensing actions may not immediately appear in federal databases, so organizations must check state medical boards to verify the status of healthcare professionals.
For more on how this applies specifically to physicians, see physician background checks.
Compare the Lists Side by Side
| List | Maintained By | Who It Covers | Update Frequency | Free / Paid | Primary Link |
|---|---|---|---|---|---|
| OIG LEIE | HHS Office of Inspector General | Individuals and entities excluded from Medicare, Medicaid, and other federal healthcare programs | Monthly (mid-month) | Free, searchable online | oig.hhs.gov/exclusions |
| SAM.gov Exclusions | U.S. General Services Administration | Individuals and entities excluded from federal contracts and grants, not healthcare-specific | Continuous, as actions are entered | Free, searchable online | sam.gov |
| State Medicaid Exclusion Lists | Each state’s Medicaid agency | Providers and entities barred from that state’s Medicaid program | Varies by state; most update monthly | Free, searchable by state | Varies by state — see note |
| NPDB | HHS Health Resources and Services Administration | Malpractice payments, licensure actions, and clinical privilege actions (not technically an exclusion list) | Continuous, as reports are filed | Restricted — self-query available; full access requires eligible-entity registration | npdb.hrsa.gov |
| DEA Controlled Substances Registration | U.S. Drug Enforcement Administration | Practitioners and entities registered, or no longer registered, to prescribe or dispense controlled substances | Continuous | Free, searchable by registrant | DEA registrant validation tool |
| OFAC & World Bank Sanctions Lists | U.S. Department of the Treasury (OFAC) and the World Bank Group | Individuals and entities tied to fraud, money laundering, or terrorism financing, or debarred from World Bank-financed projects | OFAC: near-continuous; World Bank: periodic | Free, searchable online | ofac.treasury.gov / worldbank.org |
| Professional Licensing & Medical Boards | Each state’s licensing board | Healthcare professionals with revoked, suspended, or restricted licenses | Varies by state and board | Free, searchable by state/board | Varies by state — see note |
How Often Should Healthcare Providers Screen for Exclusions?
OIG’s 2013 Updated Special Advisory Bulletin on the Effect of Exclusion recommends that healthcare providers check the LEIE monthly, matching how often OIG updates the database itself. CMS has directed state Medicaid agencies to require the same monthly cadence for state-level provider screening, and monthly has become the accepted baseline across most state Medicaid programs as a result, even though OIG’s own recommendation is guidance rather than a binding federal mandate.
A single monthly LEIE check does not cover every exposure. SAM.gov exclusions, state Medicaid exclusion lists, and licensing board actions update on their own schedules, not synchronized with OIG’s calendar, so an organization checking only the LEIE each month can still miss an exclusion posted to a state list or SAM.gov in between checks. Screening all seven lists on the same monthly cycle closes that gap without adding a second calendar to track.
What Happens If You Employ an Excluded Individual?
Federal law prohibits healthcare organizations from billing Medicare, Medicaid, or other federal healthcare programs for items or services furnished, ordered, or prescribed by an excluded individual or entity. Employing or contracting with someone on the OIG LEIE can expose an organization to civil monetary penalties under 42 U.S.C. § 1320a-7a, potential False Claims Act liability for the resulting improper billing, and repayment obligations for any federal reimbursement tied to that person’s work.
Beyond the financial exposure, hiring an excluded individual puts patients at direct risk, since exclusions frequently follow healthcare fraud, patient abuse, or a license revoked over a documented safety issue.
Exclusion vs. Sanction vs. Debarment: What Is the Difference?
The terms get used interchangeably in healthcare compliance conversations, but they describe distinct actions. Exclusion is OIG’s specific term for barring an individual or entity from federal healthcare program participation, documented on the LEIE. Sanction is the broader umbrella term for any disciplinary or punitive action taken by a federal agency, state agency, or licensing board, including exclusions, license revocations, and civil monetary penalties. Debarment is GSA’s term for barring an individual or entity from federal contracts and grants through SAM.gov, and it is not healthcare-specific.
An individual can be excluded by OIG without being debarred by GSA, or debarred without being excluded, since the two actions come from different agencies applying different legal authority. Screening against only one of the two catches only part of the risk.
How to Make Sanction Screening More Efficient
Knowing which lists to check is only half the job. See how to avoid common sanction screening pitfalls once you are screening against all seven consistently.
Challenges of Manual Sanction Screening
The standard sanction screening involves searching public databases manually; this would be required for every individual and entity. But this creates massive inefficiencies:
- Prone to Human Error: Manual checks can overlook a sanctioned individual due to typos or outdated records, which can result in compliance violations. Many individuals have multiple names, all of which must be checked to thoroughly screen them; equally, many common names may appear in lists – but could not be the individual with whom you are dealing.
- Time Intensive: Manually searching multiple databases for exclusions requires significant time and effort. This is especially true given that most searches will require multiple verifications to avoid false positives and ensure the right course of action is taken.
- Frequency of Change: Screening is never a “one and done” task; compliance with federal and state regulations requires regular checks to ensure you are not unwittingly employing excluded individuals. For example, the OIG exclusion list is updated monthly, the General SAM list is revised annually, and other lists are changed ad-hoc as new individuals or entities are added.
These issues have led many healthcare organizations to seek automated solutions that can scale their program and enable them to check all exclusion lists at least monthly – without demanding significant manual effort from their already-overworked teams.
The Role of Automated Sanction Screening Software
Automated sanction screening can save hours of manual effort each week, leveraging a range of powerful features:
- Database Integration: Healthcare compliance teams often struggle with the sheer number of exclusion lists that must be monitored, including OIG LEIE, SAM, and various state exclusion lists. Automating database integration eliminates these risks by continuously scanning multiple databases, ensuring that organizations always have the most up-to-date information on exclusions.
- Batch Processing: Many healthcare organizations work with thousands of employees, vendors, and contractors, making individual screenings a logistical nightmare. Batch processing enables organizations to screen large volumes of individuals and entities simultaneously, dramatically reducing the time and effort required for compliance checks.
- Automated Alerts: A common issue with manual screening is the delay in identifying newly sanctioned individuals, which can leave organizations exposed to compliance risks. Automated alert systems notify compliance teams immediately when a new exclusion is identified, allowing for swift corrective action before regulatory issues arise.
- Audit-Ready Reporting: Regulatory audits can be stressful, especially when documentation is incomplete or disorganized. Automated tools maintain comprehensive, detailed logs of all screenings, making it easy to generate reports that demonstrate due diligence during audits. This not only ensures regulatory compliance but also provides organizations with a structured process to handle potential investigations or disputes efficiently.
Strengthen Sanction Screening with Compliance Resource Center
Compliance Resource Center simplifies sanction screening with automated tools that eliminate manual errors and improve efficiency. Our software ensures up-to-date monitoring, batch processing, and audit-ready reports so your organization remains compliant without extra administrative burden.
Want to learn how to streamline your sanction screening process?
Frequently Asked Questions
OFAC, the Treasury Department’s Office of Foreign Assets Control, maintains the Specially Designated Nationals and Blocked Persons List, which applies full blocking sanctions to individuals and entities tied to terrorism, narcotics trafficking, money laundering, and other national security concerns. OFAC also maintains a separate Consolidated Sanctions List covering non-SDN restrictions, including the Sectoral Sanctions Identifications List and the Non-SDN Menu-Based Sanctions List, among others. Healthcare organizations with international vendors, donors, or operations should screen against both lists, not just the SDN List.
No. SAM.gov is maintained by the General Services Administration and covers exclusions from federal contracts and grants across every industry, not just healthcare. OIG’s LEIE is maintained by HHS and covers exclusions from Medicare, Medicaid, and other federal healthcare programs specifically. An individual can appear on one list, both, or neither, so healthcare organizations need to check both databases rather than treating one as a substitute for the other.
Employing an excluded individual can trigger civil monetary penalties, False Claims Act exposure, and repayment obligations for any federal healthcare reimbursement connected to that person’s work. See the penalties section above for the specific legal exposure.
Each of the seven lists in this guide is searchable directly through the agency that maintains it: OIG’s LEIE at oig.hhs.gov, SAM.gov exclusions at sam.gov, the NPDB at npdb.hrsa.gov, and OFAC’s sanctions lists at ofac.treasury.gov. State Medicaid exclusion lists and licensing board records are searchable through each state’s own health or Medicaid agency site. Organizations screening a large staff or vendor list typically use automated screening software instead of checking each source manually every month.