Healthcare Exclusion Lookup
OIG LEIE vs SAM.gov exclusions: what is the difference?
Last updated · Starry Night
Health care compliance checklists often say "check OIG and SAM". They are two different lists run by two different agencies, with different effects. Here is how OIG itself describes the difference, and how to handle both.
The short version
| LEIE (HHS-OIG) | SAM.gov exclusions (GSA) | |
|---|---|---|
| Who maintains it | HHS Office of Inspector General | General Services Administration, with records entered by many federal agencies |
| What it lists | OIG exclusions from federal health care programs only | Debarments, suspensions and other exclusions by federal agencies, including OIG's exclusions |
| Effect | No federal health care program payment for items or services the person furnishes, orders or prescribes | Depends on the agency and the type of action shown in each record |
| Detail | Legal basis, occupation, date of birth and address at exclusion | Varies by record |
| How to search | exclusions.oig.hhs.gov or the download file | SAM.gov exclusion search |
What OIG says
"GSA administers SAM, which contains debarment actions taken by various Federal agencies, including exclusion actions taken by OIG. The LEIE contains only the exclusion actions taken by OIG."
HHS-OIG, Exclusions FAQ
OIG's Updated Special Advisory Bulletin on the Effect of Exclusion (May 8, 2013) goes further. It recommends the LEIE as the primary source for OIG exclusions because OIG maintains it, updates it monthly and includes details SAM does not, such as the statutory basis of the exclusion, the person's occupation, date of birth and address at the time. OIG's exclusions staff can also answer questions about LEIE records.
The bulletin also draws a line on penalties: OIG exclusion does not affect a person's ability to take part in other government procurement, and
"OIG has no authority to impose CMPs on the basis of employment of (or contracting with) a debarred person."
OIG's Updated Special Advisory Bulletin on the Effect of Exclusion (May 8, 2013), p. 17
In other words, the civil monetary penalty for employing an excluded person (see what happens if you employ an excluded individual) is tied to OIG exclusions, which are on the LEIE.
Reading a result that appears on one list but not the other
- On the LEIE and in SAM.gov. This is the usual case for an OIG exclusion, since SAM carries OIG's exclusions. OIG recommends treating the LEIE record as the primary source, and its online search is where you verify identity with the SSN or EIN.
- In SAM.gov but not on the LEIE. The record usually comes from another federal agency's action. Read the SAM record's agency, exclusion type and dates. The health care program payment ban and the CMP for employing an excluded person described above are tied to OIG exclusions, but your contracts or grant terms may still treat a SAM record as disqualifying, so take it to whoever handles those contracts.
- On the LEIE but not found in SAM.gov. Check the spelling and former names in SAM; the LEIE is updated monthly and its record is the one OIG asks you to rely on for OIG exclusions.
- On a state list only. That is a state Medicaid action, and the state agency is the place to verify it.
Why many health employers still check both
- State Medicaid agencies must. 42 CFR 455.436 requires them to check the LEIE and EPLS at least monthly. EPLS was the federal debarment list; it is now part of SAM.gov, which GSA administers.
- Contracts may require it. State Medicaid provider agreements, managed care contracts and federal contracts or grants may name SAM.gov. Read yours.
- Federal funding. Organizations that receive federal contracts or grants have their own reasons to check SAM, separate from health care program rules.
How to check each
- LEIE: search names on OIG's online search (five at a time) or screen a full roster against the download file, then verify any possible match with the SSN or EIN on OIG's site. See how to check the OIG exclusion list.
- SAM.gov: use the exclusions search on sam.gov. Review each record's agency, type and dates.
- State lists: add the state Medicaid lists that apply to you.
- Keep a dated record of each check. See what to keep on file.
For the LEIE and state lists in one run
The screening record page screens up to 500 names at once against the LEIE and 11 state Medicaid lists (NY, CA, TX, MI, GA, MD, LA, AR, KY, NC, WA), with name matching that handles word order, middle names, nicknames and small typos, and builds a dated PDF record of the run. On-screen results and a PDF marked PREVIEW are free; a $19 one-time unlock removes the watermark for 24 hours. Names are not stored.
This site does not search SAM.gov. The record page states this, and its PDF lists only the lists actually screened. Run your SAM.gov check on sam.gov and file it alongside the record.
Questions
Does SAM.gov include OIG exclusions?
Yes. OIG's FAQ says SAM contains debarment actions taken by various federal agencies, including exclusion actions taken by OIG. The LEIE contains only OIG's exclusion actions.
Which list does OIG recommend for OIG exclusions?
OIG's 2013 bulletin recommends the LEIE as the primary source for OIG exclusions, because OIG maintains it, updates it monthly and includes more detail, such as the legal basis, occupation, date of birth and address at the time of exclusion.
Does this site search SAM.gov?
No. The screening record page and the connector search the LEIE (and, on the record page, state Medicaid lists). Check SAM.gov separately on sam.gov.
This guide explains public rules and OIG guidance in plain English. It is not legal advice; for a decision about a specific person or claim, talk to your health care counsel. Healthcare Exclusion Lookup is published by Starry Night and is not affiliated with HHS-OIG, CMS or any state agency.