Monthly OIG LEIE + SAM.gov exclusion screening: what is actually required
The NCQA 2025 update, what “monthly” really means, and how to keep dated evidence auditors will accept.
The rule, plainly
You cannot bill federal or Medicaid dollars for services rendered by an excluded provider. Not once. Not “by mistake.” Recoupment demands run into six figures, plus civil monetary penalties.
What monthly means
OIG says monthly. NCQA’s 2025 update clarified that a point-in-time check at hire is not enough - you must re-check every current provider each month against LEIE and, where applicable, SAM.gov and your state’s exclusion list.
What auditors want to see
- A dated report per provider per source per month.
- A named reviewer for any potential match.
- A written disposition explaining why a name match is not the excluded person (name + DOB + NPI reconciliation).
Why spreadsheets fail here
False positives are the killer. Common names produce weekly matches that require review. A spreadsheet cannot enforce that review happened or preserve the versioned artifact when the underlying list changes.
How ClinicWarden Module B handles it
We run scheduled screens against OIG LEIE, SAM.gov, NY OMIG (when configured), plus an attestation workflow for other states. Every check has a source, a date, and a reviewer. Match review is a first- class UI, not a comment on a spreadsheet.