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Keelstar

Guide

How to Document False Positive OIG Matches

By Keelstar Team · Updated July 11, 2026

The short answer

A false positive OIG LEIE match occurs when a name search returns a potential hit that identifier comparison disproves — different date of birth, address, NPI, or specialty from your party's records. Document every false positive with the LEIE entry reviewed, identifiers compared, disposition rationale, reviewer name, and date closed. Never dismiss a match verbally without written evidence. Capture screenshots or exports of the LEIE entry alongside your internal record. Link the disposition to the vendor or employee master so future re-screens do not trigger redundant investigations. False positive documentation is as important as confirmed match records — auditors sample both to verify your screening program works correctly, not just that you ran searches.

False positives are expected

Common names generate LEIE hits that identifier comparison disproves. A screening program that never records false positives may be failing to investigate matches — or failing to document dispositions.

Investigation steps for potential matches

When screening returns a hit, compare LEIE entry fields against your vendor or employee record before taking action.

  • Pull LEIE entry with all available identifiers
  • Compare date of birth and address
  • Compare NPI or UPIN if listed
  • Review exclusion type and effective date
  • Document side-by-side comparison

Required documentation fields

Each false positive record should answer: who was screened, what name matched, what LEIE entry was reviewed, which identifiers differed, who reviewed, and when the case closed.

When false positive is uncertain

If identifiers partially align, escalate to compliance leadership before clearing. Document uncertainty and additional verification steps — do not clear ambiguous matches to avoid delay.

Auditor expectations for match dispositions

CMS and payer auditors sample match investigations. 'We looked and it was fine' without detail fails scrutiny. Structured disposition notes with identifier comparison evidence pass.

Frequently asked questions

What identifiers resolve most false positives?
Date of birth, home or business address, NPI, general or specialty type, and exclusion effective date are the most useful LEIE fields for comparison.
Who should approve false positive dispositions?
Compliance or a designated screening analyst. High-risk vendors may require compliance leadership review before clearing.
Should we store false positive records permanently?
Yes, linked to the party's master record. Future re-screens may hit the same name — prior disposition prevents duplicate investigation.
Can we proceed before false positive review completes?
Hold payment and onboarding for billable roles during investigation. Clear only after documented disposition — not on assumption.

Related guides

Put this into a monitored workflow

Exclusion Monitor handles this continuously — with reminders and an audit trail.