A monthly exclusion screening log for everyone on staff
OIG recommends checking its exclusion list before you hire or contract with someone, and periodically after that. Because the list is updated monthly, monthly checks are the common practice. Personnel Ledger keeps a dated record of every check, person by person and month by month.
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Built from OIG's published guidance and the federal exclusion rules. General information, not legal advice. Your state, your Medicaid contracts and your payers may set rules of their own.
What OIG actually says about checking the list
The HHS Office of Inspector General keeps the List of Excluded Individuals/Entities (LEIE). In its May 2013 Special Advisory Bulletin on the Effect of Exclusion, OIG says that no statute or regulation requires a provider to check the list. It also says providers should check it before employing or contracting with someone and periodically after that, and that because OIG updates the list monthly, screening every month best limits the risk.
The risk is real even without a rule that sets the frequency:
Federal health care programs do not pay for items or services furnished by an excluded person.
42 CFR §1001.1901(b)OIG can impose civil money penalties on a provider that employs or contracts with someone it knows, or should know, is excluded.
42 CFR §1003.200(b)(4)OIG's guidance applies whether the person is an employee, a contractor or a volunteer, including per-diem staff placed by an agency.
OIG Special Advisory Bulletin, May 2013Everyone whose work could be billed to Medicare or Medicaid
Every person, not just clinicians
Employees, per-diem staff, contracted individuals, agency staff and volunteers, with office and billing staff included.
The OIG list first
The LEIE is the list OIG's guidance is about, and the one most agencies check every month.
SAM.gov, if you choose or a contract asks
Federal rules require state Medicaid agencies to check the LEIE and SAM monthly for enrolled providers. A hospice is not required to check SAM, but some payers ask for it by contract.
Your state's rules
Some states set their own duties. California's 2026 hospice regulations, for example, require an OIG exclusion clearance in the personnel record before employment, for anyone employed, contracted or paid by the hospice.
You run the search. The log keeps the proof.
OIG says providers should keep documentation of the first search and of any later ones. That is exactly what the log is.
A check for every person, every month
Exclusion screening is a requirement that renews monthly, so each new month starts with everyone due again.
Record what you found
Run the search on the official site, then record the date, the list you searched, the result and who checked. Attach the saved result if you keep one.
See who is left this month
The month's view shows who has been checked and who has not, so nobody is skipped because they work rarely.
Print any month
Print a dated log for any month to show a surveyor, an auditor or your compliance committee.
Exclusion screening, answered
Are hospices required to check the OIG exclusion list every month?
No federal rule sets a frequency. OIG recommends checking before hiring or contracting and periodically after that, and says monthly screening best limits the risk because the list is updated monthly. Your state, your Medicaid contracts or your payers may set their own rules.
Who should be screened?
Everyone whose work could be paid for by a federal health care program: employees, per-diem staff, contractors, agency staff and volunteers. OIG's guidance applies whether the person is an employee, a contractor or a volunteer.
Do we also need to check SAM.gov?
OIG does not require providers to. Federal rules require state Medicaid agencies to check both the LEIE and SAM monthly for the providers they enroll, and some payers ask providers to check SAM by contract. Personnel Ledger can log SAM checks next to the OIG ones.
What should we keep as proof of a check?
A dated record of each search for each person. OIG says providers should keep documentation of the initial search and of any later searches. The date, the list searched, the result, who ran it and a saved copy of the result cover it.
Does Personnel Ledger search the exclusion list for us?
No. You run the search on the official site, and Personnel Ledger records it and shows who is still due this month. The proof of every check stays in one place.
Does California require exclusion checks for hospice staff?
California's emergency hospice licensing regulations, in effect since June 22, 2026, require an OIG exclusion clearance before employment as part of each personnel record, and they define personnel as anyone employed, contracted or paid by the hospice. They do not set a monthly interval.
This page is general information, not legal advice. Exclusion screening expectations come from federal law, OIG guidance, your state and your contracts, and they change. Confirm your obligations with your compliance advisor.
Make next month's exclusion checks the easy part
Personnel Ledger shows who is due, records every check and prints the month. Start a free trial and log this month's checks today.