Guide
How to Screen Home Health Partners for OIG
By Keelstar Team · Updated July 11, 2026
The short answer
Home health partners — including home health agencies, therapy contractors, nursing subcontractors, and referral partners performing services billable to Medicare or Medicaid — must be screened against the OIG LEIE before engagement and on a recurring schedule. Screen legal entity names, DBAs, and key clinical and administrative principals. Home health is a high-scrutiny area for OIG enforcement; excluded agencies and individuals appear regularly on the LEIE. Document initial and recurring searches with date, list source, and result. Include home health partners in your vendor and subcontractor screening program, not just employed staff. Contract language should require partners to screen their own subcontractors and notify you of exclusion events. Confirmed exclusions require immediate cessation of referrals and billing for services furnished by the excluded party.
Home health exclusion exposure
Home health services are predominantly funded by Medicare and Medicaid. Partners who are excluded — or who employ excluded clinicians — create civil monetary penalty exposure for every claim tied to their services.
Who to screen in home health relationships
Screen broadly across the home health network.
- Home health agency legal entity
- Therapy and nursing subcontractors
- Individual clinicians on contract
- Referral and care coordination partners
- Agency owners and managing employees
Initial screening at contract signing
Complete LEIE and state list screening before executing referral agreements or admitting first shared patient. Block referrals until screening clears or false positives are documented.
Subcontractor flow-down requirements
Primary home health agency contracts should require subcontractor LEIE screening, notification of matches, and your right to audit screening records.
Recurring monitoring
Active home health partners should re-screen monthly or quarterly. New subcontractor engagement triggers immediate screening before patient assignments continue.
Documentation for survey and audit
Retain dated screening records for every partner and subcontractor. CMS surveyors and payer auditors sample home health referral and vendor files specifically for exclusion compliance.
Frequently asked questions
- Do we screen home health agencies we refer to?
- Yes, when they perform services connected to your patients and federal program billing. Referral relationships do not eliminate exclusion screening obligations.
- Should therapy subcontractors be screened separately?
- Yes. Screen subcontractors performing billable home health services on your behalf — not just the primary agency contract.
- Which state lists apply to home health partners?
- Screen state Medicaid exclusion lists for every state where the partner delivers services to your patients, in addition to the federal LEIE.
- How often should home health partners be re-screened?
- Monthly or quarterly for active partners with ongoing patient care relationships.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.