Healthcare Exclusion Screening
Screen healthcare employees and contractors against the OIG exclusion list, SAM.gov, and 320+ global sanctions and watchlist databases. Protect your organisation from civil monetary penalties and programme exclusion.
Healthcare Exclusion: A Critical Compliance Obligation
Healthcare organisations that participate in federal healthcare programmes — Medicare, Medicaid, TRICARE, and other government-funded health plans — are prohibited from employing or contracting with individuals and entities that have been excluded from these programmes. The US Department of Health and Human Services Office of Inspector General (OIG) maintains the List of Excluded Individuals and Entities (LEIE), which is the primary exclusion database for federal healthcare compliance.
Exclusion from federal healthcare programmes can result from a range of offences including healthcare fraud, patient abuse, felony convictions related to healthcare, controlled substance convictions, and licence revocations. The System for Award Management (SAM.gov) maintains a broader exclusion list covering all federal procurement and non-procurement programmes, including healthcare.
The penalties for employing an excluded individual are severe. Under the Civil Monetary Penalties Law, healthcare entities face penalties of up to USD 100,000 per item or service provided by the excluded person, plus an assessment of up to three times the amount claimed. In the most serious cases, the employing organisation itself can be excluded from federal healthcare programmes — effectively ending its ability to receive Medicare and Medicaid payments.
Who Must Be Screened
The OIG's guidance is clear: healthcare organisations must screen all individuals and entities that directly or indirectly provide services in connection with federal healthcare programmes. This includes physicians, nurses, allied health professionals, administrative staff, billing staff, contractors, temporary workers, and vendors. The scope extends to any individual whose work is reimbursed, in whole or in part, by federal healthcare funds.
Many state Medicaid programmes maintain their own exclusion lists in addition to the federal OIG and SAM.gov lists. Some states require that healthcare organisations screen against both federal and state lists monthly, and report any matches immediately. For international healthcare organisations — including those in the GCC operating US-accredited facilities or serving US-insured patients — screening against US exclusion lists is a risk management necessity even when not a direct regulatory requirement.
Healthcare Screening in the GCC
The GCC's healthcare sector includes a significant number of internationally accredited hospitals and clinics that serve patients from around the world. Many of these facilities maintain accreditation from Joint Commission International (JCI) and operate under quality and compliance standards that include employee screening against sanctions and exclusion databases.
Healthcare regulators in the UAE — including the Dubai Health Authority (DHA), the Department of Health Abu Dhabi (DOH), and the Ministry of Health and Prevention (MOHAP) — require healthcare professionals to hold valid licences and undergo background verification. Adding sanctions and exclusion screening to this process provides an additional layer of protection against individuals who have been excluded from healthcare practice in other jurisdictions.
Wirestork's screening covers OIG and SAM.gov exclusion data as part of a broader 320+ database check that also includes OFAC SDN, Interpol, PEP databases, and international sanctions lists — providing comprehensive coverage for healthcare organisations operating across multiple jurisdictions.