the searchable database as one of the matching
criteria, so those numbers are not provided by
the OIG to the searcher.
Documenting the results is extremely
important. The search results should be
printed or saved electronically into the file
that involves that contract. If there is a match,
the page indicating whether the identity was
verified should be printed as well. The database includes a unique physician identification
number (UPIN) created by the Centers for
Medicare and Medicaid Services (CMS) as a
provider identifier in lieu of a Social Security
number. The database also includes national
provider identifiers (NPIs), which have
replaced the UPIN as unique numbers used
for providers. CMS began assigning NPIs in
2006, thus some of the individuals and entities
that are excluded by the OIG do not have NPI
numbers. If a search result does not contain
a date of birth, UPIN, NPI, or Social Security
number, it is not available from the OIG. If
contacted, the exclusion staff can determine if
there is other identifying information available. A copy of the individual’s or entity’s
exclusion notice can be obtained by submitting a written request with a printout from the
LEIE to the OIG Exclusions Department.
In the System for Award Management
(SAM), various agencies, including the OIG,
list debarment actions they have taken. SAM
includes names of individuals or entities that
have been debarred, suspended, or otherwise
excluded from various federal programs. The
SAM website is available at http://www.sam.gov. As
with the OIG exclusion search, the website
has user guidelines and resources available
to assist with searches. The OIG recommends
using its LEIE as the primary search engine for
exclusions, 5 because the LEIE contains more
specific details and is updated more regularly.
Exclusion searches are a necessary part of
any contracting with healthcare providers.
Compliance can assist the provider or organization with necessary steps to conduct the
searches. For contact and support, the OIG has
resources available to help providers avoid
running afoul of federal requirements.
1. 42 U.S.C. § 1320a- 7 (Exclusion of certain individuals and entities
from participation in Medicare and State health care programs).
2. 42 C.F.R. § 1001.2 (Definitions)
3. Office of Inspector General: Exclusions Program, List of Excluded
Individuals and Entities. Available at https://oig.hhs.gov/exclusions
4. HHS, OIG, Office of Investigations, Attention: Exclusions, P.
O. Box 23871, Washington, DC 20026. Sanction@OIG.HHS.gov;
(202) 691-2311; Fax: (202) 691-2298
5. Updated Special Advisory Bulletin on the Effective Exclusion from
Participation in Federal Healthcare Programs. May 8, 2013. Available