Guide
How to Prepare OIG Evidence for CMS Review
By Keelstar Team · Updated July 11, 2026
The short answer
CMS reviewers expect proof that your organization screens employees, contractors, vendors, and medical staff against the OIG LEIE on a defined schedule — with complete records for sampled parties. Prepare evidence packages covering the review period: screening dates, LEIE list versions, names searched, results, match dispositions, and overdue exceptions with resolution. Organize by population — employees, vendors, medical staff — matching typical CMS sample methodology. Include your written screening policy, risk tier definitions, and re-screen calendar. Export structured logs — not email screenshots — with cover sheets summarizing total parties screened, confirmed matches, false positives, and overdue screens. Retain match investigation files with identifier comparison notes. Gap-free evidence on first request prevents expanded review scope.
Understand CMS review scope
CMS surveyors and contractors evaluate whether you maintain an effective exclusion screening program — not just whether you searched once. They sample employees, vendors, and contractors across a defined period.
Core evidence components
Every CMS evidence package should include these elements.
- Written OIG screening policy with frequencies
- Initial onboarding screening records
- Recurring re-screen logs with LEIE version dates
- Match investigation and disposition files
- Overdue screen exceptions with resolution
- Subcontractor and vendor screening coverage
Organize by auditor sample type
Structure exports to match how CMS samples: by employee roster, vendor list, or date range. Include a cover sheet with population totals and exception summary.
Match investigation documentation
For any potential or confirmed match in the sample period, include LEIE entry reviewed, identifiers compared, disposition, reviewer, and date closed. False positives need the same rigor as confirmed matches.
Policy and governance evidence
Provide the approved screening policy, evidence of staff training, named compliance owners, and internal audit results showing program effectiveness.
Pre-review gap remediation
Run a self-audit before CMS arrives: identify overdue screens, missing vendor coverage, and incomplete match files. Remediate and document corrective action before the review starts — not during it.
Frequently asked questions
- What does CMS ask for in exclusion screening reviews?
- Screening policy, sample of dated LEIE searches, match investigation records, re-screening evidence, and proof of onboarding screening before engagement.
- How far back should CMS evidence cover?
- Match the sample period requested — typically 12 to 36 months. Many organizations retain screening records for at least six years.
- Should we include state Medicaid list evidence?
- Yes, when CMS or your state survey scope includes state list screening. Document both LEIE and applicable state lists.
- What causes CMS to expand an exclusion audit sample?
- Incomplete records, missing re-screens, undocumented match dispositions, or gaps in vendor and subcontractor screening prompt expanded review.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.