OIG Exclusion Screening vs. SAM: What’s the Difference?

Knowing the difference between OIG and SAM exclusion screening comes down to scope. OIG (Office of Inspector General) exclusion screening checks the List of Excluded Individuals and Entities, which bars people from Medicare, Medicaid, and other federal health care programs. SAM (The System for Award Management) records government-wide debarment from federal contracts, grants, and other federal assistance. Healthcare organizations need both, because a clean result on one says nothing about the other. Here’s what each list covers, when to screen, and how to handle a potential match.

OIG exclusion screening confirms that no one involved in your federally reimbursed work is excluded from federal health care programs.

It maintains the List of Excluded Individuals and Entities, known as the LEIE. People and organizations are added to the list for reasons that include healthcare fraud convictions, patient abuse or neglect, controlled substance convictions, and license revocation or suspension. Section 1128 of the Social Security Act makes some exclusions mandatory. Others are permissive, which means OIG decides whether to impose them, but both types have the same effect once they are in place.

Under 42 CFR 1001.1901(b), federal health care programs will not pay for items or services furnished, ordered, or prescribed by an excluded person. This reaches beyond direct patient care as well as the payment itself. Salary and contract fees paid out of federal program funds fall inside the prohibition, so moving an excluded person into an administrative seat does not resolve it.

For most organizations, OIG screening needs to cover the following:

• Employees and contracted clinicians. Anyone whose work supports a billed item or service, clinical or not.
• Temporary and agency staff. Short engagements carry the same exposure as permanent roles.
• Volunteers in patient-facing roles. Unpaid status does not remove the connection to federal dollars.
• Administrative and revenue cycle staff. Schedulers, coders, and billers all touch the claim.
• Vendors and consultants. Anyone supporting billing, coding, or the systems behind them.

The System for Award Management, at SAM.gov, is maintained by the General Services Administration. Its exclusions record absorbed the older Excluded Parties List System in 2012, which is why some older compliance policies still reference EPLS by name. An entry means the individual or entity cannot receive federal contracts, grants, loans, or other forms of federal assistance.

SAM exclusions can result from actions that are not related to healthcare, such as:

• Contract fraud or misrepresentation in a federal award
• Failure to perform under an existing federal contract
• Environmental and safety violations
• Tax delinquency and other financial misconduct

Any federal agency can impose an exclusion, and once imposed, it applies across every agency rather than only the one that acted. For a healthcare organization, SAM matters in two places. It matters if you hold federal contracts or grants directly, and it matters for the vendors you contract with. SAM may include some OIG exclusions, but it is not a complete or timely substitute for checking the LEIE directly.

The table below sets them side by side on the points that change what you have to do.

The OIG and SAM databases serve different purposes, so a clean result on one does not confirm a clean result on the other. Healthcare organizations may consistently screen the LEIE while overlooking SAM, creating gaps in their exclusion screening process. Because the two databases capture different types of exclusions, screening both can provide a more complete view of potential risk.

Different agencies create the OIG and SAM lists for different reasons. As a result, a person or company can be listed on one and not the other. A nurse excluded after a Medicaid fraud conviction appears on the LEIE, but her SAM record may lag behind or never reflect it. A billing company debarred for non-performance on a federal contract appears in SAM with a clean LEIE record, because nothing it did involved a federal health care program. Screening only one list can leave other types of exclusion unchecked.

Vendors are the group most likely to appear in SAM without appearing on the LEIE. Billing companies, IT providers, suppliers, and consultants often hold federal contracts. Many also work across several industries. As a result, federal debarment actions against them are recorded in SAM. If a debarred vendor supports your billing or clinical systems, that relationship can raise questions. Screening both also removes a question you would otherwise have to answer under audit conditions.

An annual search of the LEIE shows your status on one day of the year. It would not have caught an exclusion added in March, and it gives a reviewer very little to test. Most organizations screen people before they start work and then monthly after that. The table below shows how each list updates and the schedule many organizations use.

OIG updates the LEIE once a month, so many organizations schedule their screening around that update. The following three practices help keep your schedule consistent and easy to document:

1. Fix the date. Run a few days after the monthly refresh, on the same date every month.
2. Screen the full population. Sampling new hires leaves everyone already on the roster unchecked.
3. Screen before engagement. Catching an exclusion after someone starts puts the claims tied to their work in question.

OIG’s General Compliance Program Guidance, published in November 2023, names monthly screening of the LEIE and state Medicaid exclusion lists as routine monitoring of a known risk.

Most states keep their own Medicaid exclusion list. A provider sanctioned by a state Medicaid agency may not appear on a federal list for some time, or at all. If you bill Medicaid in more than one state, you need to check each state’s list. Run those checks on the same monthly schedule as your federal searches, and record the check date for each state separately. That way, you can show a reviewer when each list was searched without piecing the dates together later.

A name match should be verified before any action is taken. Common surnames return hits belonging to somebody else entirely, and acting on one before it is confirmed creates problems of its own, employment ones included. The sequence below runs from the moment a name appears to the moment the file closes.

• Record the result as a possible match.  Name-only matches frequently resolve to somebody else, particularly with common surnames.
• Verify on an identifier. OIG SAM verification confirms a result against a Social Security number for an individual, or an employer identification number for an entity.
• Search the variants. Maiden names, former names, and known aliases before you close a search as clean.
• Send the result to the named decision-maker. Your procedure should name who makes the final determination, in addition to who runs the search. 
• Remove a confirmed match from federal program work immediately. Moving the person to a different role inside the organization does not resolve the payment prohibition. 
• Identify affected claims.  Identify every claim tied to that person’s work back to the exclusion date.
• Involve legal counsel. Talk to counsel before making an employment decision or deciding whether to self-disclose to OIG. 
• Document every step. Include the matches that turned out to be different people. Reviewers typically ask how matches were resolved, in addition to whether screening took place.

Screening programs tend to develop gaps in the same few areas. The issues below come up often when a program is reviewed.

• Screening clinical staff only. The prohibition follows the federal dollar, not the clinical role, so billing, scheduling, IT, and facilities staff sit inside it.
• Screening at hire and never again. People are excluded after they join. A pre-hire check with no monthly cycle behind it captures a single day.
• Skipping state Medicaid lists. State-level sanctions can exist with no federal counterpart, so federal lists alone leave a gap.
• Leaving vendors and contractors out. Third parties carry the same exposure as employees and almost never pass through the HR workflow that triggers screening.
• Overlooking OFAC. The Treasury Department’s Specially Designated Nationals list sits outside healthcare enforcement, which is why healthcare teams routinely miss it.
• Running it manually past a few hundred people. Typos, inconsistent scheduling, and lost documentation turn manual screening into its own audit risk.
• Working without a written match resolution procedure. Without one, you cannot show a reviewer how any individual match was investigated or closed.

Exclusion screening involves keeping records as much as running searches. Each month, a team may need to check two federal lists plus a state list for every state where it bills Medicaid, across a roster that changes as people join and leave. Manual searches can work for a small practice. As the roster grows, searches are more likely to be missed during busy months, and records often end up spread across folders and inboxes. These gaps usually surface when a reviewer asks for 12 months of screening evidence.

Healthcare compliance software runs screening on a set schedule and keeps a dated record of each search.

Compliancy Group’s Exclusion List Verification and Monitoring Tool checks employee and vendor lists against 55 exclusion lists, including the OIG LEIE, SAM, and FDA, and runs those checks weekly. It integrates with your HR information system (HRIS), so you do not have to build a new employee list by hand each month, and the team helps you verify and clear possible matches for employees and vendors. Each search is dated and stored, so you can pull a screening report when a reviewer asks for one.

The same platform carries your policies, training, risk assessments, and vendor oversight, which is what a reviewer is really testing when they ask how screening connects to the rest of your program.

The Guard—Compliancy Group’s healthcare compliance software—brings exclusion screening, vendor oversight, policies, training, and risk into one connected system, so the proof of a screen exists the moment the screen runs. Request a demo to see how Compliancy Group keeps your screening records complete and ready to hand over.