Exclusion screening is checking a person or organization against government lists of those barred from participating in federal programs or subject to sanctions. In healthcare it is not optional and not annual: employing an excluded individual exposes the employer to civil monetary penalties for every claim involving that person's work. This page sets out the lists, the cadence, and why this is a different search from a criminal check.
The lists a healthcare sanctions background check covers
The primary one for healthcare is the List of Excluded Individuals and Entities maintained by the Department of Health and Human Services Office of Inspector General, which names people and organizations excluded from participation in federal healthcare programs. SAM.gov holds the federal exclusions record covering debarment from federal procurement and non-procurement programs more broadly. State Medicaid exclusion lists exist separately and many states require them to be checked too. Sanctions screening in the financial sense runs against the Treasury's Office of Foreign Assets Control lists.
Healthcare sanction screening is monthly, not annual
The OIG's guidance to healthcare providers is to screen employees and contractors against the exclusion list at hire and then monthly, because the list is updated monthly and an exclusion imposed after hire creates exposure from the moment it takes effect. That cadence is the single most commonly missed requirement in healthcare compliance. An annual check leaves up to eleven months during which claims can be submitted for work performed by an excluded person, and the penalty exposure attaches per claim.
Why a healthcare sanctions check is not a criminal background check
Exclusion is an administrative status, not a conviction. Someone can be excluded following a conviction, but also for license revocation, defaulting on health education loans or other grounds, and the exclusion continues on its own terms after any criminal sentence ends. A criminal background check will not tell you somebody is excluded, and a clear exclusion screen says nothing about criminal history. Healthcare employers need both, plus license verification and monitoring, and they are three separate purchases.
The patriot act search, and what people mean by it
The phrase is used loosely in the screening industry to describe a search against government watchlists including OFAC's sanctions lists and various terrorist and enforcement lists. The USA PATRIOT Act itself imposes customer due diligence obligations on financial institutions rather than screening obligations on general employers. Sold as a screening product it is a watchlist search, useful in regulated financial contexts and largely decorative for an ordinary employer, so ask precisely which lists are searched before paying for it.
Questions people ask about exclusion screening
How often should healthcare employers check the OIG exclusion list?
Monthly, in line with OIG guidance, because the list is updated monthly and an exclusion imposed after hire creates exposure from the moment it takes effect. Annual screening leaves a long gap.
Does a criminal background check show an exclusion?
No. Exclusion is an administrative status that can follow a conviction but also license revocation and other grounds, and it continues on its own terms. The two searches return different things.
Which lists does a healthcare sanctions search cover, LEIE or SAM.gov?
The LEIE names those excluded from federal healthcare programs; SAM.gov holds the broader federal exclusions record covering procurement and non-procurement debarment. Many states also run their own Medicaid exclusion lists.
Is a patriot act search worth buying?
It is a watchlist search, valuable in regulated financial contexts and of limited use to a general employer. Ask exactly which lists are covered rather than accepting the product name.
What does a global sanctions background check search?
Government watchlists such as OFAC's sanctions lists and various terrorist and enforcement lists, which the screening industry also sells as a patriot act search. It matters most in regulated financial contexts, and the product name tells you little, so ask exactly which lists are covered.