Healthcare Sanction Screening in 2026: Compliance Lessons from the Last 12 Months

Between January and August 2025, 1,726 individuals and vendors were added to the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities (LEIE), which bars excluded parties from participation in Federal healthcare programs. However, the challenge for compliance teams in 2026 is not just the scale of exclusions. Rather, it is the emergence of a series of trends that will make identifying sanctioned individuals and entities more complicated.

This article explores what we’ve learned in the last 12 months—and how insights can help you prepare for more effective compliance measures in the new year.

Three Compliance Trends That Will Continue in 2026

Healthcare compliance is complex and multi-faceted, but three trends have stood out over the last 12 months:

1. Intensified False Claims Act (FCA) Enforcement

2025 saw a wave of high-profile stories about fraudulent payments and Medicare activities, with several multi-million dollar FCA enforcements across the year. In April, the Department of Justice (DOJ) announced a settlement with Walgreens for over $350 million. 

Such trends led the Department of Health and Human Services (HHS) and DOJ to join forces and create an FCA working group in July—signaling a clear intention to ramp up enforcement. Not only will they target traditional violations such as Medicare fraud and kickbacks, but also less well-trodden territory like violations of network adequacy requirements and electronic health record (EHR) manipulations.

The implications of this extend beyond FCA compliance. FCA enforcements routinely lead individuals and vendors to be added to the LEIE; several high-profile additions were made in 2025 following various improper Medicare claims.

As a result, 2026 will likely see a rapid increase in FCA-related exclusions. Compliance teams will need to be prepared to respond swiftly by identifying newly excluded individuals and entities and ensuring they are removed from any engagement with your organization.

2. Geopolitical Uncertainty

From international sanctions to trade disruptions, the last 12 months have seen significant shifts in the geopolitical landscape. These have clear implications for the complex globalized supply chains that many healthcare organizations rely on.

A simple example is the recent BIOSECURE Act, which prohibits federal agencies from contracting with pharmaceutical companies that use equipment or services from certain Chinese entities. 

There is little sign these trends will abate in 2026. Managing large vendor networks—for everything from technology to pharmaceuticals—will present clear compliance challenges, especially regarding exclusions. 

Renewed emphasis will be necessary to ensure organizations do not contract with entities featured on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) and Blocked Persons Lists. However, research indicates that only 38 percent of organizations have processes in place to check that list before onboarding new employees, vendors, or volunteers.

3. Increased Enforcement for Small Organizations

Sanction screening is often viewed as a challenge for large, multi-location organizations with  extensive workforces and vendor networks. Yet, 2026 showed that exclusion lists really do apply equally, regardless of organizational size.

A slew of recent fines—such as $35,000 for CareLink Home and $41,000 for Advanced Healthcare Services—show that a failure to run adequate checks can be costly for smaller organizations. 

The challenge lies in balancing this awareness with the significant burden of running thorough checks across multiple, complex exclusion lists.

Healthcare Compliance in 2026: How to Scale Sanction Screening 

Our experts suggest three key steps to meet sanction screening requirements in the new year:

1. Expand Your List Coverage Beyond the Basics

Most healthcare organizations screen against the LEIE because it is required. However, relying solely on HHS exclusions creates dangerous blind spots—especially as international supply chains and geopolitical sanctions become more relevant to healthcare operations.

Why it matters: An individual excluded from a state Medicaid program might not appear on the LEIE for weeks. A vendor with ties to OFAC-sanctioned entities won’t show up at all. Each gap in your list coverage represents potential compliance exposure.

Action steps to expand coverage:

• Add OFAC’s SDN list to identify sanctioned entities in your international supply chain.
• Screen against state Medicaid exclusion lists for each state where you operate.
• Include professional licensing databases to identify revoked or suspended licenses before formal exclusions are issued.
• Match your list coverage to your risk profile based on your geographic footprint and vendor relationships.

2. Increase Screening Frequency to Match Exclusion Speed

When an average of seven new exclusions is added every business day, annual screening becomes obsolete before it’s finished. Even monthly screening leaves organizations exposed for weeks between cycles, during which excluded individuals could be providing services or making patient care decisions.

Why it matters: An exclusion that occurs the day after your monthly screening cycle creates 28 days of compliance risk. Every day you work with an excluded individual or vendor accumulates potential liability—and the settlement costs that come with it.

Action steps to increase frequency:

• Move from annual to monthly screening as an immediate first step.
• Target weekly or continuous monitoring to minimize exposure windows.
• Automate screening processes so that increased frequency does not require additional staff.
• Set up real-time alerts for new matches instead of waiting for scheduled screening cycles.

3. Reduce Manual Effort to Free Up Strategic Capacity

Sanction screening is critical, but it’s just one element of your Compliance Program. Manual screening processes consume disproportionate time—downloading lists, formatting data, running searches, managing false positives—turning compliance professionals into data entry specialists.

Why it matters: Manual screening will take up more time as you expand both the frequency and number of lists included in your checks. Automating these processes will save time and reduce your staffing burden. This extra time and capacity can be reallocated to other compliance tasks.

Action steps to automate screening:

• Implement screening software that automatically pulls updated lists and runs comparisons.
• Use automated matching algorithms to filter out obvious mismatches and reduce false positives.
• Reserve human review for genuine potential matches that require judgment.
• Document screening activities automatically to maintain audit trails without manual record-keeping.
• Calculate time savings from automation and redirect that capacity to higher-value compliance work.

Prepare for Compliance in 2026 with Automated Sanction Screening Software

The steps outlined above are crucial for robust compliance in the new year. However, many teams will struggle to put them all into practice with limited time and resources.

That’s why so many healthcare compliance leaders rely on the Compliance Resource Center. Built around 30+ years of industry expertise, our best-in-class software empowers you to:

• Screen all relevant lists frequently without adding to your workload.
• Immediately identify, escalate, and deal with new potential matches.
• Automatically verify matches and avoid false-positives.

Want to take control of your compliance program in 2026?

Book a Demo

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