Guide
How to Resolve an OIG List Match
By Keelstar Team · Updated June 1, 2026
The short answer
Treat every OIG match as a hold — stop onboarding, payment, or scheduling until resolved. Compare identifiers such as date of birth, NPI, address, and SSN last four to rule out false positives. If the match is confirmed, do not engage the party in federal-program work, escalate to legal, document remediation, and retain all search and investigation records.
Immediate actions
Place the relationship on hold: no patient contact, no system access, no payments. Notify compliance and HR leadership. Preserve the search result exactly as it appeared — do not re-run and overwrite before saving evidence.
False positive investigation
OIG LEIE entries include exclusion type, date, and sometimes general location. Compare against your subject's date of birth, NPI, UPIN legacy identifiers, address history, and employer at time of exclusion. Document each comparison in writing.
When the match is confirmed
Terminate or decline engagement. For employees, follow HR termination procedures and legal review of self-disclosure obligations. For vendors, notify procurement and AP to block payment. Assess whether any federal claims were submitted during the exclusion period — repayments may apply.
Partial matches and entities
Entity matches require checking owners and principals. A clean entity name with an excluded owner may still be problematic depending on role and federal program touchpoints. Legal should advise on ownership structures.
Communication
Limit internal communication to need-to-know. Do not alert the subject in ways that create retaliation or evidence destruction risk before legal counsel advises. External communication with payers or OIG may be required in confirmed cases.
Close the loop in the audit trail
Final record should include initial hit, investigation steps, disposition (false positive or confirmed), approver, and date. Future auditors will read this chain — make it complete.
Frequently asked questions
- A common name matched — can we proceed?
- Only after documented false-positive resolution comparing available identifiers. 'Probably not the same person' without evidence is not sufficient for auditors.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.