Exclusion Screening Log: Monthly OIG, SAM, and State List Checks for NEMT

Medicaid will not pay for a ride that an excluded driver gave, a trip an excluded dispatcher booked, or a claim an excluded biller sent. When a broker or state auditor asks how you know nobody on your payroll is excluded, this log is the answer. It covers the whole company on one roster and one monthly sheet, with space for the proof and for any name that comes back as a possible match.

How to use this template

1. Fill in Part 1 once. List your company’s legal name and trade names, the lists you search, your monthly search day, and who runs the searches.
2. Build the roster in Part 2. Put the company itself on line 1, then every owner, officer, manager, driver, attendant, dispatcher, biller, office worker, volunteer, and contractor whose work touches a Medicaid trip. The section below explains who belongs.
3. Check each new person before the first shift. Search every list, save the results, and write the date in Part 2. Maryland’s NEMT program rules say a person who is on a list cannot be hired at all.
4. Pick one search day each month. OIG posts its monthly update by the middle of the month, covering the prior month’s actions. As of September 29, 2026, the last update posted September 10, 2026. A fixed day after that, such as the 15th, keeps every month the same.
5. Search every name on every list in Part 1. Try former, maiden, and hyphenated names. On the OIG search, enter only the first few letters of each name, as OIG’s search tips advise. On SAM.gov, leave the classification filter open so records filed under another type still show.
6. Save proof of each search, including the empty ones. On the OIG search, use its Print Search Results button, because OIG says the browser’s own print function will not work. Name each file with the list, the person, and the date.
7. Mark each result in Part 3. A possible match goes to Part 4 the same day, and the person stays off Medicaid trips until it is settled.
8. Collect proof from contractors in Part 5 if they screen their own staff.
9. Sign Part 6 each month. Someone other than the searcher checks the searcher’s own name. Maryland does not accept a self-check, and the split makes the log more believable to any auditor.

Keep the monthly sheets and saved results together. The same results can go in each person’s file too, using Part 4 of the driver file checklist.

The template

Part 1: Company and lists

Field	Write the entry here in pen
Company legal name
Trade names (DBA)
EIN (last four digits only)
NPI and Medicaid provider ID
Brokers and health plans you work with
Your state’s Medicaid exclusion list (name and web address)
Other states’ lists, for staff who lived or worked there
Monthly search day
Person who runs the searches
Person who searches that person’s own name
Where the saved results are kept

Part 2: Screening roster

No.	Full name, plus former, maiden, or hyphenated names	Role	Start date	Checked before start (date, initials)	End date
1	Company legal name:	E
2
3
4
5
6
7
8
9
10
11
12
13
14
15

Role key: E, the company itself. O, owner of 5 percent or more. M, officer, director, or managing employee. D, driver. A, attendant. S, dispatcher, scheduler, or office staff. B, billing or bookkeeping. V, volunteer. C, contractor or subcontractor.

Part 3: Monthly screening log (one sheet each month)

Month and year	OIG list last update shown	SAM.gov searched (date)	State list last update shown	Searched by

No.	Name or names searched	OIG list (LEIE)	SAM.gov	State list	Other state list	Proof file name
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

Result key: C, clear (no record found). P, possible match (fill in Part 4 today). X, confirmed match. N, not searched (write why).

Part 4: Possible match follow-up (one per match)

Field	Write the entry here in pen
Roster number and name
List where the record appeared
Record details (name, date of birth, address, excluding agency)
Exclusion type, start date, and end date shown
How it was checked (SSN or EIN on the OIG search, last four SSN on a state list, call to the agency)
Result: same person or not the same person (date, initials)
Date the person was taken off Medicaid work
Broker told (name, date, and how)
State Medicaid agency told (date and how)
Trips, claims, and pay during the exclusion period reviewed (dates covered)
Health care attorney consulted (name and date)
OIG self-disclosure filed (date), or the reason it was not
Case closed (date and signature)

Part 5: Contractors who screen their own staff

Contractor	What they do for you	Month covered	Lists their proof covers	Proof received (date, initials)

Part 6: Monthly sign-off

On ______________ (date), every name on the roster in Part 2 was searched on every list in Part 1. The searches found ____ possible matches, each followed up in Part 4. The saved results are kept at ______________.

Searched by (signature and date)	Searcher’s own name checked by (signature and date)	Reviewed by the owner (signature and date)

Who has to be on the log

Exclusion reaches far past the driver’s seat. OIG’s special advisory bulletin (May 8, 2013) says excluded people may not provide transportation that a federal health care program pays for, naming ambulance drivers and ambulance company dispatchers as examples. They also may not do administrative or management work that Medicaid pays for, even when it is not billed separately. That includes executive roles, an office manager, billing and accounting, staff training, and human resources.

Federal Medicaid law points at NEMT directly. Section 1902(a)(87) of the Social Security Act, added by section 209 of the Consolidated Appropriations Act, 2021, makes each state ensure that every NEMT provider and every individual driver it pays is not excluded. CMS’s transportation guide (SMD 23-006, September 28, 2023) adds that transportation providers must screen their employees, whether the state enrolls the company or its individual drivers.

Who	Why they are on the roster
The company, under its legal name and trade names	MTM Health’s standard agreement (January 1, 2023 version posted by Pennsylvania) has you warrant that neither the company nor its owners or officers are on any federal or state excluded parties list
Owners of 5 percent or more, officers, and directors	Your state must check each person with an ownership or control interest at least monthly (42 CFR 455.436). OIG’s bulletin says a provider that is 5 percent or more owned by an excluded person can itself be excluded
Managing employees, such as an operations or dispatch manager	The state checks them too. A managing employee is anyone with operational or managerial control over day-to-day operations, W-2 or not (42 CFR 455.101)
Drivers and attendants	Section 1902(a)(87). MTM’s agreement bars any driver or attendant on the OIG list, EPLS, or a similar list
Dispatchers, schedulers, and call takers	OIG’s bulletin and CMS letter SMDL #09-001 both name dispatchers
Billers, bookkeepers, and office staff	Billing, accounting, and management work Medicaid pays for is covered
Volunteers	OIG applies the same risk to volunteers as to employees
Contractors, such as a billing service, staffing agency, or partner company that takes your overflow	OIG says to screen contractors and their employees with the same test you use for your own staff

OIG’s test is simple: if Medicaid pays, directly or indirectly, for any part of the work, screen everyone in that job. You may rely on a contractor’s own screening, but OIG says to confirm it by asking for and keeping their records. Either way, any overpayment for work by an excluded person is yours to repay. Screening is one piece of a compliance program, and broker credentialing will ask to see it.

Which lists to check and how often

OIG’s bulletin says no statute or regulation makes providers check its list. It still tells providers to check before hiring and then periodically, and it says monthly checks best limit overpayment and penalty risk. The rules that make it mandatory come from CMS, the states, and your broker contracts.

• CMS. Letter SMDL #09-001 (January 16, 2009) told states to require providers to search the OIG list monthly and to report any exclusion they find right away. It also told states with their own lists to remind providers to search them whenever they search the OIG list.
• Texas. Screening every employee and contractor every month is a condition of Medicaid enrollment (provider manual, September 2026). Health plans must check each driver, and each employee who works directly with members or sees their records, against the OIG list and SAM monthly (Uniform Managed Care Manual 16.4, version 2.0.1).
• Pennsylvania. Screen at hire and monthly after, against the Medicheck List, the OIG list, and the federal list now in SAM (MA Bulletin 99-11-05, August 15, 2011). If a worker’s resume shows another state, check that state’s list too.
• Louisiana. The broker searches the OIG list, the Louisiana Adverse Actions List, and SAM every month, and reports any exclusion to the state within three business days (Medicaid manual chapter 10, issued July 14, 2025).
• Georgia. Every Medicaid provider must search the Georgia exclusion list, the OIG list, and SAM before hiring and every month (Georgia DCH exclusions page, September 2026).
• Maryland. Transportation providers send the local grantee a monthly attestation with screenshots of the OIG and Maryland sanctioned provider list results (MDH policy PT 36-09, updated September 1, 2018). See the Maryland state guide.

List	Kept by	How to search	How to confirm a match
OIG List of Excluded Individuals/Entities (LEIE)	HHS Office of Inspector General	Online, up to five names at once, or a full monthly download for a long roster	Enter the SSN or EIN in the online search. The download has no SSNs or EINs
SAM.gov exclusions	General Services Administration	Search, then choose the Exclusions domain. No login is needed	Read the full record and contact the excluding agency named in it
Your state’s Medicaid list	Your state Medicaid agency or inspector general	See the table below	Each state’s own steps

The OIG list holds only OIG’s own exclusions. SAM holds OIG’s exclusions plus debarments by other federal agencies. The OIG exclusion list and SAM exclusion check pages walk through each search screen by screen.

Some state lists, as posted in September 2026:

State	List	What to know
Arizona	AHCCCS State Exclusion List	A posted file of current exclusions, most recently effective September 25, 2026
Florida	AHCA Public Record Search	Choose Medicaid Sanctioned Providers
Georgia	Georgia OIG Exclusions List	A spreadsheet updated at least monthly, most recently September 16, 2026
Illinois	HFS Provider Sanctions	Search online through the Provider Sanctions Search page
Iowa	Iowa Medicaid Sanctions List	Iowa says to check it, the OIG list, and SAM at hire and monthly, under every name a person has used
Louisiana	Adverse Actions List Search	The broker checks it monthly
Maryland	Maryland Medicaid sanctioned provider list	Searched monthly with the OIG list. It includes some sanctions, such as a revoked license, that never reach the OIG list
New York	OMIG Medicaid Exclusion List	Search up to five names at once, or download the full list or a list of exclusions from the last 30 days
Pennsylvania	Medicheck List	Updated daily. Verify a possible match with the last four digits of the SSN or the 9-digit FEIN
Tennessee	TennCare Terminated Provider List	Posted on the TennCare program integrity page and updated as needed
Texas	Texas Exclusions List	Texas HHS OIG says every provider should check it monthly
Washington	HCA Provider termination and exclusion list	Lists providers whose Medicaid participation was terminated for cause

What counts as proof

A date in a column is not proof. Keep the saved result behind every entry.

• OIG says to keep the first name search, such as a printed screenshot of the results, and every extra search you ran to confirm a possible match.
• Pennsylvania wants documentation an auditor can follow: the date of each screening, the list checked, and that list’s most recent update date. Part 3 has a column for each.
• Maryland requires the first and monthly searches saved as screenshots or electronic files for six years. It does not accept documentation from anyone who checked their own name, and its local programs may not let the person who runs the searches search or attest to their own name.
• Texas health plans must keep proof of every screening and hand it to the state on request, and no one may provide NEMT services while a required check is past due. Services by anyone who was not eligible are recouped.

If you ever have to disclose an excluded employee to OIG, its Self-Disclosure Protocol (amended November 8, 2021) asks you to describe your screening process, any background checks you ran, and the flaw that let the person through. A complete log answers most of that.

When a name matches

A match on a job applicant is simple: do not hire or contract with them. Maryland’s rules say such a match needs no report, because the person cannot be employed. A match on someone already working for you takes these steps.

1. Confirm it before you act. OIG says a matching first and last name is not enough. Open the record, enter the person’s SSN, or the EIN for a company, and save the verification result. On Pennsylvania’s list, check the end date first: a past end date means the person is no longer excluded.
2. Pull the person from all Medicaid work. No federal health care program pays for any item or service an excluded person furnishes, whoever submits the claim (42 CFR 1001.1901).
3. Report it as your state and broker require. Texas tells providers to report exclusion information right away. Pennsylvania says to self-report immediately to its Bureau of Program Integrity. MTM’s agreement requires immediate notice if any owner, officer, director, or manager is placed on an excluded party list.
4. Work out what was paid. CMS counts as an overpayment the Medicaid money spent on the person’s services, including salary, expenses, and benefits paid with Medicaid funds (SMDL #09-001).
5. Get legal advice on disclosure. Before using OIG’s Self-Disclosure Protocol, you must screen all current employees and contractors, then disclose every excluded person in one submission. For matters other than kickbacks, the minimum settlement has been $20,000 since November 8, 2021.

The penalty for using a person you knew, or should have known, was excluded is steep. Under the HHS adjustment published January 28, 2026, OIG can seek up to $25,595 for each item or service the person provided (45 CFR 102.3), plus up to three times the amount claimed (42 CFR 1003.210). For work that is not billed on its own, such as dispatching, the assessment can reach three times your total cost of employing them, salary and taxes included. OIG can also exclude your company. For how exclusion cases fit with other audit findings, see NEMT fraud.

How long to keep the log

Rule	How long
MTM Health standard agreement (January 1, 2023 version posted by Pennsylvania), full records of your operations	10 years, or longer if law or the client requires
Maryland NEMT program, policy PT 36-09 (updated September 1, 2018), first and monthly search results	6 years
Texas health plans (Uniform Managed Care Manual 16.4), proof of every screening	No set period: kept at headquarters and given to the state on request

The longest rule that applies to you wins. Keep the log for as long as you keep the trip records it protects, and see NEMT record retention for one schedule that covers everything.