OIG LEIE vs. SAM.gov Exclusion List Monitoring
There are two main federal exclusion datasets, in addition to the 42 state Medicaid exclusion lists. As one might imagine, these lists don’t always share information well or have a clear overlap between information necessary to confirm matches and exclusions given limited employee or entity data.
While considering the differences in searching and matching in these two divergent databases, it reminds us of choosing between the Android operating system and the Apple iOS system. Similar to operating systems, some federal data sets are easier than others to conduct, search, match, and determine if a possible record can be linked to your employee, vendor, or owner. The way you go about searching and finding the references you need can be a little tricky given the complexities and usability of each database or website. Let’s take a look a little further into how to quickly search and match with each federal exclusion database – OIG LEIE and SAM.gov.
What is the SAM Exclusion List?
The SAM.gov launched in 2012 and was formed under a mandate from the Affordable Care Act in an attempt to create one broader dataset of individuals and entities that are debarred, sanctioned, or excluded from doing business under a federal contract. The acronym SAM stands for the System for Award Management and includes several federal contracting databases (including USDA-FNS, TREAS-OFAC, OPM, HHS, and more) but the most significant one for healthcare providers is the Government Services Administration’s list of Excluded Parties List System (GSA-EPLS). The EPLS consists of federal contractors who have been debarred, sanctioned, or excluded due to government contract issues or fraud.
If an individual or entity is on the EPLS list, a healthcare company should not be in contractual privity with such person or company as it would be conducting business with a sanctioned, debarred, or excluded party. HHS OIG and the Centers for Medicare and Medicaid Services (CMS) have both made it clear that no federal healthcare dollars should be paid to (directly or indirectly) reimburse, in whole or in part, the services, items or salaries/benefits.
What is the OIG LEIE?
In addition to SAM.gov, The other federal exclusion list is the Office of Inspector General’s List of Excluded Individuals and Entities (OIG-LEIE). This list has been in existence since the early 1990’s and is a compilation of those persons and/or entities that have been excluded from participation in federal healthcare programs such as Medicare and Medicaid. The LEIE was designed to include all exclusions from each state. However, OIG audits show that the LEIE is missing up to 61% of exclusions at the state level. The Office of Inspector requires each state to report their exclusions in a timely manner according to Performance Standard 8 and Section 1128 of the Social Security Act. Unfortunately, the discrepancies between state and federal exclusion data still present a challenge for healthcare professionals looking to identify excluded employees and vendors.
How to Search and Match the OIG LEIE Exclusion List
The OIG LEIE allows you to search by an individual’s first and last name, or by the full entity / third party name. The site allows you to search for up to 5 multiple names or entities at a time. Simply enter the data and if a possible name(s) are in the OIG-LEIE, you will be prompted to enter a Social Security Number for an individual to determine if it is a match (A federal Employer Tax ID is not necessary to determine a match for an entity). Let’s walk through this step to give you a better idea.
Take, for instance, this example of Mr. Godfrey.
Step 1: Enter the First and Last Name
Step 2: View Search Results and Verify Each Name
Step 3: Verify Each Name or Entity with a Social Security Number (SSN) or Employer Identification Number (EIN)
The potential risk of searching the OIG LEIE database yourself is that many times you are missing crucial information to help match each exclusion with 100% certainty. You might be lacking information like an employee’s SSN or a healthcare vendor’s EIN or TIN to narrow down results. Other common issues can occur as well (especially when you are dealing with large amounts of data) like common name matches, misspellings, or nicknames that cannot be accounted for without more unique qualifiers and supplemental information.
This is where an automated system and augmented dataset can help make this process much more simple for your organization. Consider the time alone it takes for someone to search for so many employees and healthcare vendors. Further, think about all of the possible exclusions you might be missing that have not been reported to the Office of Inspector General from each state. These critical decisions can have lasting effects that many compliance and HR departments are surprised to learn the hard way. Having a trusted partner who specializes in employee and vendor monitoring can go a long way. Click to learn more about –> exclusion monitoring solutions.
How to Search and Match the SAM Exclusion List
To find healthcare exclusions from SAM.gov, you will need to register for access. Entry and access for referencing these resources are free and open to anyone willing to search. Here are a few quick steps to get started.
Searching the OIG LEIE and SAM.gov Each Month is Best Practice
Although the OIG-LEIE and SAM.gov database are two different federal exclusion lists, both should be searched each month. Since there are gaps in reporting state Medicaid exclusion data to the OIG-LEIE, and the fact that the SAM.gov (EPLS) data is missing approximately 7% of state exclusion data on entities, a thorough search of the available 42 state Medicaid exclusion lists should also be performed each month. Rest assured that this process remains a challenge for many healthcare organizations from hospitals to dentist offices, and even healthcare staffing agencies. Having a clear conscience about who you are hiring and monitoring if you bill for Medicare or Medicaid is so vital to a successful compliance culture and quality of care. Rest assured, our software solutions have your back – please feel free to ask us any questions or give us a call to learn more!
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Written by Michael Rosen, ESQ
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as Inc. Magazine’s Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year.