Guide
How to Screen Employees for Exclusions
By Keelstar Team · Updated June 1, 2026
The short answer
Screen every employee, contractor, and volunteer who could bill or interact with federal healthcare programs at hire and on a recurring schedule. Search the OIG LEIE and applicable state Medicaid exclusion lists using legal name and aliases. Document each check with a date and result — hiring someone who is excluded exposes your organization to significant penalties.
Why employee screening is non-negotiable in healthcare
Federal law prohibits payment for items or services furnished by excluded individuals. That includes employees who submit claims, provide billable care, or support billing operations — not just licensed clinicians. An excluded employee working in any capacity tied to federal programs can trigger civil monetary penalties for each day of employment or engagement.
When to screen
Screen at offer acceptance or before start date — before system access, credentialing, or patient contact. Re-screen all active staff on your organization's schedule, typically monthly or quarterly. Also screen when legal names change, after extended leave in regulated roles, and when state licensing boards flag an issue.
Which lists to check
At minimum, search the OIG LEIE. Many states maintain separate Medicaid exclusion lists that do not sync automatically with OIG. If you operate in or serve patients from multiple states, your policy should define which state lists apply to each employee based on work location and payer mix.
- OIG LEIE — federal healthcare program exclusions
- State Medicaid exclusion lists where applicable
- OFAC SDN when employees handle international payments or vendors
Contractors, locums, and volunteers
Apply the same screening standard to temporary staff, agency placements, medical directors paid as contractors, and volunteers in billable or patient-facing roles. Staffing agencies should provide exclusion clearance documentation — but ultimate responsibility often remains with the hiring organization. Verify agency checks rather than accepting a blanket attestation.
Responding to a confirmed exclusion
Do not allow an excluded individual to perform services billable to federal programs. Terminate or reassign immediately, notify compliance and legal, and document the timeline. Self-disclosure obligations may apply depending on the circumstances. Retain all screening records showing when the exclusion appeared relative to hire date.
Integrate with HR workflows
Exclusion screening should not live in a compliance silo HR forgets to trigger. Embed checks in onboarding checklists, credentialing workflows, and periodic compliance audits. Automated re-screening catches exclusions that occur after hire — the most common gap in manual programs.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.