Quick answer: healthcare employers have to check two federal exclusion lists, the OIG's LEIE and SAM.gov, on top of a normal background check. A clean criminal record doesn't cover this. These are separate checks, and you re-run them on a schedule, not just once at hire.
That's the whole answer. Here's what each list actually is, why it exists, and how often you really need to check it.
The Department of Health and Human Services' Office of Inspector General keeps a database called the List of Excluded Individuals/Entities. Everyone just calls it the LEIE. It's a running list of people and companies barred from working in any federally funded healthcare program, Medicare and Medicaid mainly.
Someone lands on it for things like healthcare fraud, patient abuse, or losing a license over their conduct. Once they're on the list, they can't bill Medicare or Medicaid. Neither can you, for any service they touched.
SAM.gov is the federal government's System for Award Management. It's broader than healthcare. It covers anyone excluded from doing business with the federal government at all, across every agency, not just HHS.
The two lists overlap, but they're not the same list. Someone can show up on one and not the other. That's exactly why you check both. Checking only the one that sounds more "healthcare" isn't enough.
Employing someone on either list creates real exposure for you, not just for them. If you bill Medicare or Medicaid for services an excluded person was involved in, even indirectly, you can end up owing that money back.
I'm not going to hand you a specific penalty dollar figure here. It varies by case, and I'd rather not make one up. What I will say plainly: this isn't background-check theater. It's a real, well-established federal requirement with real financial teeth behind it.
Here's the part people miss. A thorough criminal background check still doesn't automatically pull the LEIE or SAM.gov. Those are separate federal databases, and most general screening packages don't check them unless you specifically ask.
If your screening provider isn't already running both for every healthcare hire, ask them directly. Don't assume "background check" means "exclusion check." Most of the time, it doesn't.
At hire, and then again on a recurring basis. Monthly is the standard most healthcare compliance programs run, because someone can get added to either list after you've already hired them.
A one-time check at onboarding doesn't protect you six months later if that employee gets excluded in the meantime. That's the piece a lot of smaller healthcare employers skip. It's not exciting work, checking a list every month for people you already hired. But it's the actual job, not the optional part.
| List | Run by | Covers | Check frequency |
|---|---|---|---|
| LEIE | HHS Office of Inspector General | Exclusion from Medicare, Medicaid, and other federal healthcare programs | At hire, then monthly |
| SAM.gov | General Services Administration | Exclusion from doing business with the federal government generally | At hire, then monthly |
Some states also run their own Medicaid exclusion lists on top of these two. If you operate in one of those states, that's a third check to add, not a substitute for the federal ones.
For a small healthcare practice, this doesn't need to be complicated. Screen every new hire against both lists before their start date. Then run the same check against your full active roster once a month, not just new hires.
Most screening providers that work with healthcare clients can automate the monthly re-check. If yours can't, that's worth asking about before you sign anything, not after you find out the hard way.
I'm confident on the two lists and the fact that this obligation is real and federally mandated. I'm not going to play lawyer on the exact penalty structure or every edge case for your specific facility type. Talk to healthcare compliance counsel for that part. The lists themselves aren't going anywhere, and they're not optional to check.