How often must healthcare providers screen for exclusions?

HHS-OIG recommends checking the LEIE before hiring or contracting and then screening every month, but states that providers are not required by statute or regulation to check it at any particular frequency. The recommendation comes from OIG's Updated Special Advisory Bulletin on the Effect of Exclusion, which says: “OIG updates the LEIE monthly, so screening employees and contractors each month best minimizes potential overpayment and CMP liability.”

Is monthly screening legally required?

Not for providers under federal statute or regulation, according to HHS-OIG: “Providers are not required by statute or regulation to check the LEIE.” The same bulletin notes that CMS's 2011 final regulations mandate that States screen all enrolled providers monthly, and that CMS clarified the regulation does not mandate States to require their Medicaid providers to screen their own employees and contractors; CMS recommends States consider doing so. If you are enrolled in a state Medicaid program, check that program's own terms.

Why does OIG recommend monthly rather than annual screening?

Because the list changes every month. HHS-OIG's exclusions FAQ states: “Both versions of the LEIE are generally updated by the middle of each month.” Our reasoning, not OIG's: a check at hiring catches only exclusions that already existed on that date, so someone hired clear can be excluded the following month, and a program that re-screens only annually can carry that person for most of a year without knowing.

Monthly roster screening on this site

Sources

• HHS-OIG, Updated Special Advisory Bulletin on the Effect of Exclusion (2013)
• HHS-OIG, Exclusions Program FAQ
• CMS, State Medicaid Director Letter #09-001 (January 2009)

Where this page says “our characterisation,” “our reasoning,” or “we measured,” the statement is CFExclusion's own rather than a government source's. CFExclusion is a private service and is not affiliated with HHS, OIG, CMS, or SAM.gov.