Guide
How to Screen Medical Staffing Vendors for Exclusions
By Keelstar Team · Updated June 1, 2026
The short answer
Screen the staffing agency as a vendor and each placed clinician before start — OIG LEIE, applicable state Medicaid lists, and SAM where federal contracts apply. Do not accept agency attestations without your own dated checks. Re-screen travelers and locums on the same cadence as direct employees because exclusions can occur mid-assignment.
Why staffing is high risk
Travel nurses, locum physicians, and allied health contractors rotate frequently, often across states. Exclusions may post after credentialing. Agency workers touch patients and charts on day one — if they are excluded, federal program liability attaches to the facility using them.
Screen the agency and the individual
The agency is a vendor — check OIG, SAM, and OFAC on the entity. Each placement is an individual — run LEIE and state lists on legal name, maiden names, and aliases before schedule release. Contract should require agency notification within 24 hours if a worker becomes excluded.
Credentialing vs exclusion screening
Credentialing verifies licenses and training; exclusion screening verifies federal and state program eligibility. They are related but not interchangeable. A licensed nurse can still be OIG-excluded. Both checks must complete before patient contact.
High-volume onboarding
Staffing firms placing hundreds of workers per month need automated screening at offer and monthly re-check — manual LEIE searches do not scale. Hospitals receiving agency workers should require screening certificates with search dates, not annual letters.
Mid-assignment exclusions
OIG updates monthly. A traveler cleared in January can be excluded in March. Re-screen agency staff on the same monthly or quarterly cycle as employees. Immediate removal from schedule if a hit is confirmed.
Contract language to require
Include obligations for pre-placement screening, continuous monitoring, immediate notification of exclusions, indemnification for false attestations, and right to audit agency screening logs. Operations only works if legal embeds these in the MSA.
Frequently asked questions
- Whose job is it — the hospital or the agency?
- Both may have contractual obligations, but the billing provider and hiring facility typically retain survey liability. Hospitals should verify, not rely on agency PDFs alone.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.