Guide
What to Do When OIG Screening Finds a Match
By Keelstar Team · Updated July 11, 2026
The short answer
A name match on the OIG LEIE is not automatic confirmation of exclusion — common names produce false positives. Stop payment and engagement activities while you investigate. Compare identifiers: date of birth, address, NPI, specialty, and exclusion effective date against your party records. If identifiers align, treat it as a confirmed match: do not employ, contract with, or pay the party for federal program-connected work, escalate to compliance and legal, and document every step. If identifiers clearly differ, document the false-positive disposition with the evidence you compared. Never proceed on verbal assurance alone — auditors expect a written resolution trail tied to the screening record.
First response: hold, do not ignore
When screening returns a potential LEIE match, place an immediate hold on payment, onboarding completion, or system access for billable roles. Continuing to pay or engage while you figure it out later creates daily penalty exposure. Notify the compliance owner and document the hold timestamp.
Investigating false positives
Compare LEIE entry fields against your vendor or employee record. Different dates of birth, states, NPIs, or addresses often confirm a false positive. Capture screenshots or export the LEIE entry and your internal record side by side. Write a disposition note explaining why the match was rejected.
Confirming a true match
When identifiers align, treat the match as confirmed. Cease all federal program-connected work immediately. Do not wait for OIG written confirmation — the LEIE publication is the authoritative source. Escalate to legal for assessment of self-disclosure, payer notification, and claim impact.
Documentation auditors expect
Every match investigation needs a record independent of the initial search: match date, LEIE entry reviewed, identifiers compared, disposition (false positive or confirmed), reviewer name, and date closed. 'We checked and it was fine' without detail fails under CMS or payer audit scrutiny.
Preventing repeat match confusion
After resolving a false positive, link the disposition to the party's master record so future re-screens do not trigger redundant investigations. For confirmed exclusions, flag the record permanently and block re-engagement unless OIG reinstatement is documented.
Frequently asked questions
- Should I terminate someone based on a name match alone?
- No. Investigate first. A name match requires identifier comparison before you confirm exclusion. However, hold payment and billable work during investigation to limit exposure.
- What identifiers help resolve false positives?
- Date of birth, home or business address, NPI, UPIN, general or specialty type, and exclusion effective date are the most useful LEIE fields for comparison.
- Who should investigate a potential match?
- Compliance or a designated screening analyst performs initial review. Confirmed matches escalate to compliance leadership and legal. HR or vendor management executes holds on employment or payment.
- Do we need to self-disclose if we find a confirmed exclusion?
- Self-disclosure obligations depend on circumstances, payer contracts, and how long the excluded party performed services. Legal counsel should assess promptly — do not delay the hold while deciding.
- Can we keep an excluded employee in a non-billable role?
- Possibly, with legal guidance — but the role must have zero connection to federal healthcare program items or services. Document the role restriction and monitor compliance.
Related guides
Put this into a monitored workflow
Exclusion Monitor handles this continuously — with reminders and an audit trail.