Guide
How to Screen Owners and Officers for OIG
By Keelstar Team · Updated July 11, 2026
The short answer
OIG exclusions attach to individuals as well as entities — screening only the company name misses excluded owners who control or perform work through the business. Screen individual owners, officers, and managing members of vendor entities when your compliance policy requires principal screening — especially for small LLCs, sole proprietorships, DME suppliers, home health agencies, and billing companies. Search legal names and aliases against the LEIE and state Medicaid lists. Document each search with date, list version, and result. Principal screening complements entity screening: a clean entity name with an excluded owner still creates exposure if that person performs billable or program-connected work. Include principal screening in vendor onboarding for high-risk tiers and re-screen on your recurring schedule.
Why entity screening alone is insufficient
Excluded individuals often continue operating through corporate shells or small businesses registered in a non-excluded entity name. OIG expects providers to look through entity structure to individuals who perform or control program-connected services.
Collect ownership information at onboarding
Request owner and officer names, titles, and ownership percentages in your vendor onboarding packet. You cannot screen principals you have not identified.
- Owner and officer disclosure form
- Beneficial ownership for small entities
- Managing member names for LLCs
- Updated disclosure on ownership changes
How to search individual principals
Use legal names from ownership disclosure and W-9. Search LEIE with full name, then aliases and former names. Compare date of birth and address against potential matches.
Risk-based principal screening tiers
Screen all principals for high-risk vendors — billing, DME, pharmacy, home health. For lower-risk large corporations with passive ownership, document your rationale if principal screening is not performed.
Re-screening owners and officers
Include identified principals in recurring re-screen batches. Trigger immediate re-screen upon ownership change notification or acquisition.
Document principal screening for audit
Log each owner search separately from entity search: name searched, date, result, and disposition. Auditors sample whether you screened individuals behind small vendor entities.
Frequently asked questions
- When is owner screening required?
- Common for small entities, sole proprietorships, DME suppliers, billing vendors, and any vendor where owners perform operational or clinical work. Define requirements in your written policy.
- Do we need ownership percentages to screen?
- Policy varies — many organizations screen all owners above a threshold (e.g., 5% or 20%) and all officers with management authority.
- What identifiers help resolve owner name matches?
- Date of birth, address, NPI, and exclusion effective date from the LEIE entry compared against your vendor ownership disclosure.
- Should owners be re-screened on schedule?
- Yes. Include identified principals in your monthly or quarterly re-screen roster alongside entities.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.