Blog Post

Common Pitfalls in the Sanction Screening Process and How to Avoid Them 

October 2025

Working with individuals or vendors featured on exclusion lists can lead to fines, frustration, and serious reputational harm. The Office of Inspector General (OIG) has settled cases for up to $300,000 with healthcare organizations that failed to sufficiently screen candidates for inclusion on these lists, making this a vital part of any effective compliance program.1

This article explores why sanction screening is so important and how you can avoid common errors that lead to inaccurate, infrequent, and ineffective processes. But first, let’s establish how screening fits into the larger picture of healthcare compliance.  

What Are the OIG Compliance Guidelines? 

The OIG’s Compliance Program Guidance (CPG) helps healthcare organizations prevent, detect, and respond to fraud, waste, and abuse.22 It establishes seven fundamental elements:  

  1. Written policies and procedures 
  2. Designated compliance officer and committee 
  3. Effective training and education 
  4. Open communication lines 
  5. Internal monitoring and auditing 
  6. Enforcement through disciplinary guidelines 
  7. Prompt response with corrective action 

Sanction screening is an integral component of this framework, particularly within internal monitoring, auditing, and enforcement standards. The CPG requires organizations to establish systematic processes to identify and exclude sanctioned individuals before their participation in federal healthcare programs.3 

The takeaway is simple: regular, accurate screening is an ongoing compliance obligation for all healthcare organizations. Every employee, vendor, and volunteer must be screened upon first contact with your organization, and ongoing monthly screening is essential to keep pace with updates to exclusion lists.4 However, based on our experience, several common challenges often arise in the screening process. 

Five Common Pitfalls in the Sanction Screening Process 

Compliance Resource Center has spent the past 15 years helping healthcare organizations implement, manage, and optimize sanction screening programs. As a result, we’ve seen firsthand how many healthcare organizations struggle with the following common challenges:  

1. Poor Data Quality and Record-Keeping 

Sanction screening typically relies on text matching to identify individuals. However, this method is highly vulnerable to human error. A single typo in an employee or vendor’s record could result in a failed match when searching the OIG’s List of Excluded Individuals and Entities (LEIE) for the wrong name—leading to a false negative and potential compliance risk. 5

Data could be incorrectly entered, outdated, or simply missing, but the result is the same: inaccurate screening outcomes. We have found that providers often change names, relocate, or have name variations across databases. Despite this,  many organizations, especially those using manual screening processes, lack the bandwidth to run exhaustive checks for multiple aliases across lists. As a result, they risk overlooking sanctioned individuals. 

2. False Positives 

Many individuals on exclusion lists have common names, and anyone with the same name may be flagged by a manual search. This can even be true of vendors; despite copyrighting their names, many companies still have generic names that could easily be mistaken for another business.  

These false positives require further investigation to verify, making the process taxing for compliance teams. They must analyze supporting information to determine whether the apparent match is real. Worse still, because false positives are always a possibility, any positive match must be carefully verified. 

3. Screening Gaps 

The LEIE and General Services Administration’s System for Award Management (SAM) are the most important exclusion lists for healthcare compliance, and more than 70% of organizations successfully check them.6 However, these lists are far from exhaustive. Healthcare organizations are also subject to numerous additional lists. 

In our experience, most organizations overlook at least a few relevant lists, such as TRICARE, the Drug Enforcement Agency’s (DEA) Excluded Parties List, or state-level exclusion lists. The sheer number of lists can be overwhelming for overworked teams, and scaling screening is unfeasible using manual processes. 

4. Inconsistent Screening Frequency 

Screening is often seen as part of onboarding, rather than an ongoing requirement. However, exclusion lists, such as the LEIE, are regularly updated, often monthly. This means individuals or vendors who were not excluded at the time of hire may later appear on one or more lists.  Continuing to work with those individuals could result in serious violations that could lead to five-figure fines.7 

The problem is exacerbated by two factors:  

  1. Exclusion lists have different update cadences, with some changing only every few months or annually. This makes efficient screening complicated; compliance teams must adopt different screening schedules depending on the list they are looking at. 
  2. Many organizations use manual systems to keep track of screening. This makes it difficult to determine when screening was last undertaken. As a result, the screening could be delayed, missed entirely, or performed inconsistently – creating compliance risk.  

5. Lack of System Integration 

While manual screening processes are often inefficient, automation alone does not guarantee effective compliance.  A common issue is a lack of interoperability with HR systems, credentialing platforms, or vendor management systems. 

Without integration, automated systems can lead to a false sense of security. Compliance teams may assume screening has been performed, but the screening software was not updated with new hire information. As a result, employees or vendors may enter the organization without proper vetting. 

How Can Healthcare Organizations Avoid These Pitfalls? 

Our experience suggests the pitfalls outlined above are very common and create serious compliance risks. Fortunately, they can also be reliably overcome with the following steps: 

1. Make Screening a Priority 

Research shows that sanction screening is the area of compliance that healthcare organizations are most confident about. However, that same research also reveals that very few organizations use all relevant exclusion lists.8 This tension can lead to screening being overlooked or undervalued, and fixing that problem is the first step toward establishing a robust program.  

Make your intention to improve screening explicit; there must be cultural buy-in around prioritizing accurate screening. We suggest either sending an internal memo about screening or demonstrating this renewed commitment through actions, such as introducing new tools and policies. 

2. Establish Official Screening Protocols 

Many organizations already have policies around screening, but they are often outdated or miss key factors in the process. Organizations should establish new policies and procedures that clearly define: 

  • The full range of exclusion lists that must be checked 
  • The frequency with which screening must be performed 
  • The process for verifying and validating positive matches 
  • The next steps to follow once an individual or vendor is found to be excluded 

3. Introduce Automated Software 

Many of the pitfalls discussed above are exacerbated—or actively caused—by manual processes that are time-consuming, prone to error, and very unpopular within compliance teams. Eliminating them not only improves the speed and accuracy of screening but also increases morale in your compliance department.  

Modern automated screening systems can run large batch screening in seconds that would take humans hours of manual effort. The ideal system would also include:  

  • Comprehensive screening across all exclusion lists 
  • Automated processes to verify matches 
  • Real-time alerts to ensure matches are dealt with quickly 
  • Integration with other systems, such as HR onboarding tools 

Unfortunately, most platforms on the market do not meet these criteria, which is why we created the Compliance Resource Center. 

Our sanction screening solution combines best-in-class automated software with expert support to reduce the burden on your team and eliminate factors that make screening difficult.9 The result? A faster, simpler, more cost-effective approach to screening that protects your company from compliance risk and gives your staff more time to focus on other mission-critical tasks. 

Want to see the platform in action?  

Schedule a Consultation

Resources

  1. Van Halem Group. (2024, December 4). What is the OIG’s List of Excluded Individuals/Entities (LEIE) database — and why should I care? Van Halem Group. https://www.vanhalemgroup.com/blog/post/what-is-the-oig-s-list-of-excluded-individuals-entities-leie-database-and-why-should-i-care-/
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  2. Office of Inspector General (U.S. Department of Health & Human Services). (2023, November 6). General compliance program guidance. HHS–OIG. https://oig.hhs.gov/compliance/general-compliance-program-guidance/ ↩︎
  3. Compliance Resource Center. (2025, September). Healthcare sanctions screening: How to run effective background checks. https://www.complianceresource.com/blog/healthcare-sanctions-screening-how-to-run-effective-background-checks/
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  4. Compliance Resource Center. (2025, May). Volunteer screening: A guide to background checks in healthcare. https://www.complianceresource.com/blog/how-to-screen-volunteers-in-healthcare/ ↩︎
  5. Compliance Resource Center. (2025, May). Volunteer screening: A guide to background checks in healthcare. Compliance Resource. https://www.complianceresource.com/blog/how-to-screen-volunteers-in-healthcare/
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  6. SAI360. (2022, June). 2021 Healthcare Compliance Benchmark Survey. SAI360. https://www.sai360.com/wp-content/uploads/2022/06/2021-sai360-healthcare-compliance-benchmark-report-pdf.pdf ↩︎
  7. Office of Inspector General, U.S. Department of Health & Human Services. (2011). 42 CFR § 1003.102 – Basis for civil money penalties and assessments. https://www.govinfo.gov/content/pkg/CFR-2011-title42-vol5/pdf/CFR-2011-title42-vol5-sec1003-102.pdf
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  8. SAI360. (2022, June). 2021 Healthcare Compliance Benchmark Survey. https://www.sai360.com/wp-content/uploads/2022/06/2021-sai360-healthcare-compliance-benchmark-report-pdf.pdf
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  9. Compliance Resource Center. (n.d.). Sanction screening services & software – OIG LEIE, GSA SAM. Compliance Resource Center. https://www.complianceresource.com/sanction-screening/
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