How to Screen the OIG and Considerations to Improve Your OIG Screening
Once you understand why you must screen for excluded providers via the OIG LEIE, the first step is the most simple, you must go to the “Search Exclusions Database” page on the Office of Inspector General Health and Human Services (OIG HHS) website. That page can be found at the following link; https://exclusions.oig.hhs.gov.
Before we begin, this article will be designed as a cheat sheet for those required to screen the OIG LEIE (List of Excluded Individuals and Entities). However, before we begin explaining the process to screen individuals through the OIG LEIE website, it is important to note that this article will not be designed to explain what an OIG Exclusion is. Fortunately for those of you who were hoping for an explanation on OIG Exclusions, Paul Weidenfeld, a leading authority on Healthcare Compliance, has already written a two-part whitepaper which can be found via the following links. Providers Guide to the OIG. For those of you who are still confused or have questions about what an OIG Exclusion is, I strongly suggest you first take the time to read the whitepaper as it will give you strong core knowledge required to understand the screening process.
If you follow the OIG link provided in the first paragraph of this article, it will take you the following landing page: 
The first thing to note about the “Search the Exclusions Database” page on the OIG HHS website is that there are four options for screening against the LEIE Database available. Those four options are highlighted via arrow in FIGURE 1 and are “Search For An Individual”, “Search For Multiple Individuals”, “Search For A Single Entity”, and “Search For Multiple Entities”. The rest of this article will be formatted into sections, corresponding to the four options in FIGURE 1 that are offered on the OIG HHS website. Each section will describe, with helpful insights and detail, how to screen the OIG for each option.
Our FREE Consultation has you covered. It includes: An overview of exclusions in addition to an overview of your specific requirements and obligations. Furthermore a demonstration of our product and service (SAFER) will be performed prior to a presentation of your personalized solutions. This consultation is a free of charge consultation for your benefit only!1. How to Screen the OIG for a Single Individual
If you once again take a look at FIGURE 1, you will see the landing page for “Search For A Single Entity.” Once you reach this landing page, you will be able to screen one individual by first and last name against the LEIE database. Once you have entered a last and or first name, simply click “search” to screen that combination of first and last name. For example, if you wanted to screen an individual named “John Doe”, you would fill out the search as shown in Figure 2 below, and then click search.
Once you click the search button, one of two things will happen. That combination of first and or last name will either produce results or not. If you were to follow through with the above example of John Doe, your search will not produce results but rather a landing page, portrayed in Figure 3, that clearly states “No results were found for…”
Before we move on to what to do about a search that produces results, it is important to note that if you do not enter the official name of the individual provided to the OIG, your search will not produce proper results. There are a few tips and tricks that are vital to properly screening the OIG LEIE database:
- Make sure that you have the proper spelling of the name of the individual you are trying to clear. The OIG LEIE database does not account for misspelled names and will not retrieve the proper results.
- When it comes to long, complex last names, it is best to use only a portion of the last name because as long as there are no incorrect letters, the database will produce the proper results.
- “$ % ! * #” all cannot be used in the database search. However, apostrophes, ampersands, and commas can be used but only when present in the individual (or entities).
- If an individual has a hyphenated last name, you should screen against all possible combinations of first and last names.
If you were to conduct a search that produces no results, it is recommended that you review the above tips to determine that the at question individual is not on the OIG LEIE. In the circumstance that you adjust the name and produce a result from the OIG LEIE or screen an additional name that produces results, it then becomes your responsibility to verify whether or not the at question individual is a match to the individual with the same name on the LEIE. For example, John Miller, is a common name and does in fact produce results on the list. If you were to enter, “John Miller” into the search bar, in the exact same fashion you entered “John Doe” in Figure 1, it produces these results;
As mentioned above, John Miller is a common name and, as you can see in Figure 3, therefore actually produces multiple results. Once you have conducted a search that produces a result, you are provided with some additional information to help determine whether or not there is a match to the at question individual. That additional information is a middle name, general information about their profession, their medical speciality, and exclusion type. Despite this additional information, we suggest you always verify all potential matches by SSN when available. As you can see in Figure 3, to the right of each potential match is a button labeled “verify.” When you click that button, it will take you to a screen that allows you to enter a Social Security Number (SSN) that screens that SSN against the one on file for the excluded individual. Once you enter the at question individual’s SSN and click search, the search engine will take you to the landing page with either “NO MATCH” or “MATCH” in colorful, bold letters.
In certain situations, the OIG will not have a SSN on file for an excluded individual or entity. In those situations, OIG suggests that you get the at question individual to sign an affidavit that states they are not the same individual as the one excluded per the OIG LEIE.
2. How to Screen the OIG for Multiple Individuals
The second possibility on the OIG LEIE database is the “Search Multiple Individuals.” The process for searching multiple individuals is almost the exact same as searching for a single individual except you can run up to five names at once. When you click on the link for “Search Multiple Individuals,” it takes you to the following landing page.
As you can see, the landing page is the same landing page as “Search For An Individual” but with five slots for first and last names opposed to one. The process, again, is the same process as searching an individual but when you screen up to five names, you can receive mixed results. What this means is, you may conduct searches that produce both no potential matches for some names while producing potential matches for others. In those situations, the results will be presented in the following fashion:
As you can see in Figure 5, when searching for multiple individuals, those names will be placed on top of the results page with the header “results were found for” with the name of the individual with potential matches listed just below. Furthermore, if an individual does not produce results, they will be listed below those names with results with the header “No Results Found For.” In those situations, a name produces no results, it is once again suggested to review the aforementioned tips to make sure you did not make an error or mistake which led to no results being produced for a potential match. Finally, if you have an individual or name that produces potential matches, you must once again follow the steps explained above for using an SSN, or affidavit, to verify whether an individual matches the individual listed on the LEIE.
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Once again, the process for searching a single or multiple entities is essentially the same process with the same tips and tricks for searching for a single or multiple individuals. The landing pages for these search options, as presented in Figure 6 and Figure 7, look about the same as the individual search landing pages except that instead of first and last names as the search criteria, there is simply “entity name.”
Once you have reached the correct landing page, either single or multiple, you then must fill in at least the first few letters of the companies or entity you are trying to screen. Again, review the tips above to ensure you are entering the correct name for the at question entity or entities. If you have reviewed the above tips and still have not produced any results, you have completed your responsibility and there is not anything else to be done. In those situations that results are produced by a search, the results will reveal as follows:
As you can see in Figure 8, which is an example of a search for multiple entities, once again the entities that produced results are on the top. Those without results are presented below that with a separate header. Finally, those potential matches to a screened entity will appear at the bottom of the screen. These potential matches will present you with the option to verify. When verifying a potential match to an entity, it is important to remember to use the FEIN/EIN/TIN opposed to the SSN. Only by using the correct identification number will you be able to retrieve good results.
4. Considerations to Improve Your OIG Screening
First off, those who are excluded and are in the OIG LEIE Database do whatever they can to avoid detection. This has manifested in a variety of ways such as using a nickname for their first name, reverting to their maiden name, utilizing hyphenated or two-part last names, and other methods to present themselves as having a name not on the OIG LEIE.
The reverse side of the above issue is that is the user’s responsibility, not the responsibility of the OIG, to ensure that you are screening the OIG properly. An example of this is a hyphenated last name such as Deegan-Smith. An individual with the last name Deegan-Smith is known to Exclusion Screening as an excluded individual. However, if you search only the last name Deegan on the OIG LEIE website, it will not bear results. You, as the user, are responsible for properly screening hyphenated names even if certain searches of the individuals name bear no results.
Furthermore, it is supposed to be that if someone gets excluded from State Medicaid, they also get added to the OIG LEIE. However, we have found that this is not the case and it can take years for an excluded individual to be added to the OIG LEIE after being excluded by a state. What does this mean? It unfortunately means that if you are not checking State Medicaid Exclusion Databases, you could very well employ or do business with an individual or entity excluded in another state. This can not only lead to further legal and financial ramifications, but also means you are employing or doing business with an individual or entity that has committed patient abuse/neglect, controlled substance violations, or committed healthcare fraud.
These unfortunate but severe considerations lead to one simple recommendation, us a third-party/service to perform your exclusion and sanction screening checks. Third-party services such as Exclusion Screening, LLC were developed and designed to directly address the compliance process and potential problems laid out in this article. If you are looking for a service that will automate this process and allow for a hands-off compliance experience, Exclusion Screening, LLC is the service for you!
5. Additional Considerations and Comments
Once you have completed any of the available search options, it is recommended by the OIG that you print those results, regardless of whether there are potential matches, and keep it in that individual or entity’s file. This way, you can show authorities, in the instance you get audited, that you took traceable efforts to screen individuals and entities.
Furthermore, through our experience at Exclusion Screening, we have learned that those individuals and entities excluded by the OIG often take efforts to avoid detection. Individuals and entities will go by nicknames, middle names and “doing business as” names so that when they are screened on the OIG LEIE database, there are no results. This can become tricky and detrimental if you end up hiring or doing business with an excluded individual or entity.
Fortunately, we, at Exclusion Screening, LLC have taken all the difficulties, tricks, and confusing aspects of screening the OIG LEIE and other exclusion databases when creating our proprietary software, SAFER. SAFER screens against all federal and state exclusion lists while accounting for nicknames, middle names, “doing business as” names and misspellings when screening against the exclusion databases. For more information on our services, fill out the form below or schedule a demo today!