Ongoing Compliance
Continuous monitoring of federal and state exclusion lists (OIG, SAM, Medicaid) to ensure compliance and protect against regulatory penalties.
Screening once at hire isn't enough, new exclusions are added monthly. Ongoing monitoring is required.
The lists
Exclusion lists are databases maintained by federal and state agencies that identify individuals and entities barred from participating in government programs, contracts, or federal healthcare reimbursement. Employing someone on an exclusion list can result in severe financial and legal consequences.
The federal List of Excluded Individuals and Entities, managed by the HHS Office of Inspector General. Individuals and entities excluded from federal healthcare programs (Medicare, Medicaid). For anyone billing Medicare/Medicaid.
The System for Award Management federal exclusion list for individuals and entities barred from federal contracts or assistance. Managed by GSA. For federal contractors, subcontractors, and grant recipients.
State-specific exclusion lists for providers barred from state Medicaid programs, separate from the federal OIG list. For healthcare providers operating in states with Medicaid programs.
Individuals and firms debarred by the FDA from drug development, manufacturing, or distribution. For pharmaceutical companies and clinical research organizations.
Why it matters
Exclusion monitoring is not optional for entities that bill federal programs or receive federal contracts. It's a legal requirement with serious financial and reputational consequences for non-compliance.
Federal law requires healthcare providers and government contractors to screen employees and contractors against exclusion lists. Failure can result in penalties, loss of contracts, and criminal liability.
Employing an excluded individual means any federal payments tied to their work can be recouped, resulting in millions of dollars in repayment liability.
Individuals can be added to exclusion lists at any time, not just at hire. A one-time check is not sufficient; ongoing monitoring catches mid-employment exclusions.
During audits you must demonstrate that you screened at hire and maintained ongoing monitoring. Documentation of continuous screening is required to defend against violations.
The stakes
Exclusion screening is an active audit focus for healthcare providers and contractors. The risk is not abstract, and a one-time check does not provide an ongoing defense.
These are the consequences organizations can face when exclusion screening breaks down.
Who needs it
Required for any organization that bills federal healthcare programs, receives federal contracts, or operates under FDA oversight.
| Industry | Description | Requirement |
|---|---|---|
| Healthcare Providers | Hospitals, clinics, physician practices, nursing homes, home health, pharmacies, and any entity billing Medicare or Medicaid. | Mandatory (federal law) |
| Government Contractors | Federal contractors and subcontractors, grant recipients, and any entity receiving federal funding or contracts. | Mandatory (FAR requirements) |
| Pharma & Medical Device | Drug manufacturers, clinical trial sponsors, and medical device companies subject to FDA oversight. | Mandatory (FDA regulations) |
| Healthcare Staffing Agencies | Agencies placing healthcare workers in facilities that bill federal programs. | Mandatory (derived from client requirements) |
When you configure compliance rules for a position, PSBI automatically includes the appropriate exclusion lists based on your industry: healthcare gets OIG + state Medicaid, federal contractors get SAM, pharma gets FDA debarment. You don't manually select lists.
How it works
Exclusion monitoring runs continuously in the background. You don't need to remember to check lists manually or schedule periodic searches. The system handles it.
All employees and contractors are screened against relevant exclusion lists at hire or onboarding. A clean result is documented for audit purposes.
Once hired, the employee is added to continuous monitoring. Their identifiers are checked against updated exclusion lists on a regular basis (monthly or more frequently).
If a monitored individual appears on an exclusion list (new exclusion or match discovered), an alert is generated immediately.
The compliance team, HR, or other designated recipients receive alerts via email and dashboard, including match details and recommended next steps.
The organization investigates the match (confirm identity, determine exclusion scope) and takes appropriate action (termination, reassignment, contract termination).
Cadence
Monitoring frequency depends on the list and your industry's risk tolerance. PSBI supports flexible schedules.
Standard frequency for most organizations. OIG updates the LEIE monthly; SAM updates daily but monthly checks are generally sufficient. Recommended for: healthcare providers, standard compliance.
More frequent monitoring for high-risk environments or large workforces where the cost of an undetected exclusion is high. Recommended for: large hospitals, high-volume billing, CIAs.
Continuous monitoring that checks against updated lists as they're published, for the fastest possible alert. Recommended for: organizations under CIAs, maximum risk mitigation.
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Learn more →Real people
PSBI is owner-operated and US-based, screening organizations since 1995. When an exclusion match needs judgment, a real specialist helps you confirm and act, not a ticket queue.
FCRA-compliantOwner-operated since 1995Based in Ashland, WIGet started
Tell us your industry and enrolled population. We'll apply the right federal and state lists and the monitoring cadence your compliance program requires.
