| Function | Population it owns | Screen before | Ongoing |
|---|---|---|---|
| Human Resources | Applicants, employees, students, trainees, volunteers, and consultants the Practice engages | An offer is extended, a start date is set, or a consultant is engaged | Every cycle |
| Medical Staff Office / Credentialing | Practitioners and allied health professionals, employed or not, including locums and telehealth | Appointment, privileges, or reappointment is granted | Every cycle, plus each reappointment |
| Supply Chain / Purchasing | Vendors, suppliers, and their personnel furnishing items or services | A purchase order issues or a contract is signed or renewed | Every cycle for active vendors |
| Billing / Revenue Cycle | Practitioners billed under, billing and coding contractors, and outside practitioners whose orders, referrals, or prescriptions the Practice fills or bills | The first claim is submitted, and for outside orders at the point of service | Every cycle |
| Practice Leadership / Governing Body | Owners, officers, members of the board of directors, and members of the board's committees, including governance committees | Election or appointment, or an ownership interest is acquired | Every cycle |
| Compliance Office | The whole population, by reconciliation against payroll, the medical staff roster, the volunteer, student, and trainee list, the vendor master, the ownership, officer, board, and board committee roster, and staffing agency placement lists; and every other function's screening, by validation | Any gap is found | Each cycle, confirm every function's screen ran on its whole population and was documented; quarterly reconciliation |
| Source | What it catches that the others do not | Cadence |
|---|---|---|
| OIG LEIE | Exclusion from all federal health care programs. The primary source OIG recommends for exclusion screening | Monthly |
| SAM.gov exclusions | Government-wide debarment and suspension, a separate authority from exclusion, so a person or entity debarred by another federal agency may not appear on the LEIE | Monthly |
| CMS Preclusion List | Medicare Advantage and Part D preclusion is separate from OIG exclusion. Direct list access is restricted; coordinate with the applicable plan and retain notices or screening evidence rather than claiming a public lookup | Monthly coordination and on receipt of notices |
| State Medicaid exclusion lists | Practitioners and entities a state has suspended or terminated, whether or not they are also federally excluded. See Exhibit B for the list each state maintains | Monthly, for every state the Practice participates in |
| State licensing board discipline and license status | Board sanctions, suspensions, restrictions, and lapsed licenses; in California a revoked or suspended license, or one surrendered while a disciplinary hearing is pending, automatically suspends the practitioner from Medi-Cal as of that date (Welf. and Inst. Code 14043.6(a)) | At hire, at credentialing, and at each renewal |
| NPDB | Malpractice payments and adverse licensure, privileging, and professional society actions reported nationally. Query rights are limited to eligible entities | At appointment and reappointment |
| DEA registration | Registration status, restrictions, and surrenders for prescribers | At hire and at each renewal |
| FDA Debarment List | Firms and persons debarred under section 306(a) or (b) of the Federal Food, Drug, and Cosmetic Act, as listed on FDA's debarment list for drug product applications | Where the Practice manufactures, distributes, or handles drugs or devices, or conducts clinical research |
Why monthly. OIG advises monthly screening to reduce exclusion exposure. The monthly database-check duties in 42 CFR 455.436 apply to state Medicaid agencies; Practice duties also depend on state rules and contracts. This policy adopts monthly screening as a Practice control. Assess exposure using the exclusion effective date in the official record, not the posting or discovery date. Targeted correction: September 5, 2026.
Before you act on a match. Common names produce false positives, and taking adverse action on an unverified match creates its own liability. Confirm identity first. Where [Practice Name] uses a third-party background screening vendor that is a consumer reporting agency, coordinate the adverse action steps with counsel before acting. On a confirmed match, exposure, including the cost of work that is not billed separately, is calculated from the exclusion effective date, not the date you discovered it.