Guide
How to Screen Contractors for OIG Exclusions
By Keelstar Team · Updated July 11, 2026
The short answer
Independent contractors who perform billable or program-connected work are subject to the same OIG exclusion rules as employees. Screen every contractor before engagement using legal name and aliases against the LEIE and applicable state Medicaid lists. Medical directors, locum tenens, billing consultants, and IT contractors with claims system access all require screening — not just clinicians at the bedside. Document each check with date, list source, and result. Re-screen on your organization's schedule because a contractor cleared at contract signing can be excluded later. Treat agency attestations as supplemental, not a substitute for your own dated search records.
Why contractors are in scope
Federal law prohibits payment for items or services furnished by excluded individuals — regardless of whether they are W-2 employees or 1099 contractors. Medical directors paid as contractors, per-diem nurses, coding consultants, and revenue cycle freelancers all create exclusion exposure if not screened.
Which contractors to prioritize
Apply risk-based prioritization but do not assume non-clinical contractors are exempt.
- Physicians and advanced practice providers on contract
- Locum tenens and per-diem clinical staff
- Billing, coding, and revenue cycle consultants
- IT contractors with EHR or claims system access
- Administrative contractors supporting enrollment or credentialing
How to search contractors on the LEIE
Use the contractor's legal name as it appears on the contract and tax documents. Search aliases, former names, and professional names used in practice. For contractors operating through an entity, search both the business name and the individual performing the work when your policy requires principal screening.
Contractor onboarding checklist
Embed OIG screening in your contractor intake process alongside credentialing, contract review, and system provisioning. Block system access and payment until screening completes and is documented. Include re-screening obligations in contract language so contractors expect periodic checks throughout the relationship.
Handling confirmed exclusions
Do not allow an excluded contractor to perform services connected to federal healthcare programs. Terminate or suspend the engagement immediately, notify compliance and legal, and document the timeline. Retain all screening records showing when the exclusion appeared relative to the contract start date.
Re-screening contractors on schedule
Contractors excluded after onboarding are a common audit finding. Schedule recurring LEIE checks aligned with your employee screening cadence — monthly or quarterly for high-risk contractors. Automated re-screening prevents gaps when compliance teams turnover or contractor rosters grow.
Frequently asked questions
- Are 1099 contractors treated the same as employees for OIG screening?
- Yes, for exclusion purposes. If a contractor performs services connected to federal healthcare program billing or operations, you must screen them regardless of employment classification.
- Do I need to screen contractors who only work remotely?
- Remote work does not reduce exclusion exposure. If the contractor touches billing, coding, care delivery, or systems tied to federal programs, screen them.
- What if the contractor is placed through a staffing agency?
- Request exclusion clearance documentation from the agency, but verify with your own LEIE search. Ultimate compliance responsibility often remains with the hiring organization.
- When should contractor screening happen?
- Before contract execution or first payment — whichever comes first. Re-screen on the schedule defined in your compliance policy, typically monthly or quarterly for high-risk roles.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.