# OIG Exclusion List: What NEMT Providers Must Check and How Often

Canonical URL: https://nemtguide.com/glossary/oig-exclusion-list/ · Updated 2026-09-28

The OIG exclusion list, officially the List of Excluded Individuals/Entities (LEIE), names the people and companies barred from Medicare, Medicaid, and other federal health programs. Medicaid will not pay for any service an excluded person provides, including driving, dispatching, billing, and management. NEMT providers check every owner, employee, and contractor before hiring and then every month, the schedule CMS asked states to require in 2009.

- Medicaid will not pay for any service an excluded person provides, from driving and dispatch to billing.
- Screen every owner, employee, and contractor before hiring, then every month after OIG updates the list.
- Check the LEIE, SAM.gov, and your state's own list, and confirm any name match with an SSN or EIN.
- Employing an excluded person can cost up to $25,595 per item or service under the January 2026 HHS adjustment.
- Keep dated proof of every search, since it is your evidence in an audit.

## What the OIG exclusion list is

The HHS Office of Inspector General (OIG) excludes people and companies under section 1128 of the Social Security Act, with rules in 42 CFR parts 1001 and 1003.

A conviction for Medicare or Medicaid fraud, patient abuse or neglect, felony health care fraud, or a felony drug crime brings a mandatory exclusion of at least five years. OIG can also exclude for other reasons, such as a lost health care license. Reinstatement is never automatic.

## Why it matters for NEMT

Medicaid will not pay for any service an excluded person provides, whoever bills for it. Section 1902(a)(87) of the Social Security Act also makes states confirm every NEMT provider and driver they pay is not excluded.

OIG's May 8, 2013 bulletin says that covers driving and dispatching, plus billing, accounting, human resources, and executive roles. An excluded owner may not manage the business or do its billing.

Hiring or contracting with someone you knew or should have known was excluded can cost up to $25,595 for each item or service they provided, under HHS's inflation adjustment of January 28, 2026. OIG can add up to three times the amount claimed and exclude your company.

## How often to screen

Screen before you hire, then every month. OIG updates the list monthly and says monthly checks best limit your risk. OIG says no federal law or regulation makes providers check. The rule comes from CMS and the states:

- **CMS** letter SMDL #09-001 (January 16, 2009) told states to require monthly searches. Its guide SMD #23-006 (September 28, 2023) says transportation providers must screen employees.
- **Texas** makes monthly screening a condition of Medicaid enrollment (Texas Medicaid manual, September 2026).
- **Pennsylvania** says to screen at hire and monthly after (MA Bulletin 99-11-05, August 15, 2011).

Your state checks you and your owners monthly too (42 CFR 455.436). Screening is part of [staying enrolled](https://nemtguide.com/guides/how-to-become-a-medicaid-transportation-provider/).

## Other lists to check

The LEIE shows only OIG's actions. CMS tells states with their own lists to have providers search them too.

| List | Kept by | Notes |
|---|---|---|
| [SAM.gov exclusions](https://sam.gov/search/?index=ex) | General Services Administration | Federal debarments, including OIG exclusions |
| [Texas Exclusions List](https://oig.hhs.texas.gov/exclusions) | Texas HHS Inspector General | Texas says to check it monthly |
| [Medicheck List](https://www.pa.gov/agencies/dhs/report-fraud/medicheck-list) | Pennsylvania Department of Human Services | Updated daily, and downloadable |
| [Adverse Actions List](https://adverseactions.ldh.la.gov/SelSearch) | Louisiana Department of Health | Health plans check NEMT providers against it, the LEIE, and SAM monthly (2026 manual) |

## How to search the LEIE

**Online.** The [LEIE search](https://exclusions.oig.hhs.gov/) takes up to five names at once. Enter the first few letters, and try former and hyphenated names. A name match is not proof. Click Verify, enter the Social Security number or EIN, and save the result with Print Search Results.

**Download.** For a full roster, compare the monthly [LEIE file](https://oig.hhs.gov/exclusions/leie-database-supplement-downloads/) in a spreadsheet. It lacks Social Security numbers and EINs, so confirm possible matches online. The September 10, 2026 update covers actions through August.

## What to do if you find a match

1. **Confirm it** with the SSN or EIN.
2. **Stop the work and billing.** Take the person off all Medicaid-paid work, and bill nothing they provided while excluded.
3. **Report it.** Pennsylvania and Texas both want it reported to the state. Check your [broker](https://nemtguide.com/glossary/nemt-broker/) contract too.
4. **Settle past payments.** Medicaid money paid for their work, salary included, is an overpayment. To settle the federal penalty risk, use OIG's [Self-Disclosure Protocol](https://oig.hhs.gov/compliance/self-disclosure-info/self-disclosure-protocol/). Screen everyone first, then report all matches at once. Since November 8, 2021, its minimum settlement is $20,000.

## Records to keep

OIG and Pennsylvania say to keep proof of every search.

| Record | What it shows |
|---|---|
| Screening roster | Everyone you check, including owners and the company, with role, hire date, and SSN or EIN |
| Monthly results | Each saved search, its date, the list's last update, and any SSN or EIN check |
| Screening policy | Who checks, how often, and against which lists |
| Contractor proof | Screening records from contractors that check their own staff |

## Frequently asked questions

### Is monthly exclusion screening required by law?

Not by federal statute or regulation, OIG says. It still urges a check before hiring and every month after, because it updates the LEIE monthly and that timing best limits your penalty risk. States turn it into a rule. CMS asked every state in 2009 to require monthly searches, and Texas makes monthly screening a condition of Medicaid enrollment. Louisiana's health plans check NEMT providers every month too.

### Can someone on the exclusion list own a NEMT company?

An exclusion does not directly ban ownership, but it is risky. OIG may exclude a company that is 5 percent or more owned by an excluded person. The excluded owner cannot do any work Medicaid pays for, including management and billing. An excluded person who keeps that ownership, or serves as an officer or managing employee, can face a penalty of up to $25,595 per day under the HHS inflation adjustment published January 28, 2026.

### Do I have to screen my billing company or other contractors?

OIG recommends it for any contractor whose work Medicaid pays for, and names billing and coding companies as an example. You can rely on the contractor's own screening instead, but OIG says to confirm it and keep copies of their records. Either way, the risk stays with you if an excluded person works on your rides or claims.

### What is the difference between the LEIE and SAM.gov?

The LEIE lists only exclusions made by HHS OIG. SAM.gov, run by the General Services Administration, lists debarments from many federal agencies, including OIG's exclusions. OIG recommends the LEIE as your main source because it is updated monthly and shows more detail, such as the legal basis for each exclusion. Louisiana's health plans check both lists, plus the state's own.

## Official resources

- [HHS OIG: Search the exclusion list (LEIE)](https://exclusions.oig.hhs.gov/)
- [HHS OIG: Download the LEIE file](https://oig.hhs.gov/exclusions/leie-database-supplement-downloads/)
- [HHS OIG: LEIE search tips](https://oig.hhs.gov/exclusions/leie-quick-tips-instructions/)
- [SAM.gov: Search federal exclusions](https://sam.gov/search/?index=ex)
- [HHS OIG: Health Care Fraud Self-Disclosure Protocol](https://oig.hhs.gov/compliance/self-disclosure-info/self-disclosure-protocol/)
- [Texas HHS OIG: Search the Texas Exclusions List](https://oig.hhsc.state.tx.us/oigportal2/Exclusions)
- [Pennsylvania DHS: Search the Medicheck List](https://www.humanservices.dhs.pa.gov/Medchk/)
- [Louisiana Department of Health: Adverse Actions List Search](https://adverseactions.ldh.la.gov/SelSearch)