OIG LEIE vs SAM.gov Exclusions: What Each List Covers

A vendor onboarding form says "screened against exclusion lists," and the box is ticked. Which lists? For a health care organization the honest answer is often "the OIG one." For a federal contractor it is often "SAM." Each answer leaves a gap, because the two lists are run by different agencies, for different programs, and say different things about the people on them.

This post lays out what each list covers, where they overlap, and where a third list, the OFAC SDN list, fits in. If you want to check a name now, our free SAM.gov exclusion search searches up to 25 names at once, and the combined exclusion check searches OIG, SAM.gov and OFAC together.

The OIG LEIE

The List of Excluded Individuals and Entities is published by the Office of Inspector General at the US Department of Health and Human Services. It lists people and companies that OIG has excluded from participating in federal health care programs.

An exclusion on the LEIE means federal health care programs, including Medicare and Medicaid, will not pay for items or services the excluded party furnishes, orders or prescribes. That reaches anyone who employs or contracts with the excluded party, not only the party itself, and OIG can impose civil monetary penalties on organizations that employ or contract with excluded people.

OIG updates the LEIE every month. Each record carries a name, an address, an exclusion type tied to the section of the Social Security Act it was imposed under, and an exclusion date. Many records have no NPI, so most matches come down to a name, and confirmation happens on exclusions.oig.hhs.gov with an SSN or EIN.

SAM.gov exclusions

The System for Award Management, at SAM.gov, is run by the General Services Administration. It is where entities register to do business with the federal government, and it holds the government-wide record of exclusions.

An exclusion in SAM.gov means the party has been suspended, debarred, proposed for debarment or otherwise excluded by a federal agency. Depending on the record, that bars the party from federal contracts, from subcontracts under federal contracts, and from many kinds of federal financial assistance such as grants and cooperative agreements. Procurement exclusions fall under FAR subpart 9.4, and nonprocurement exclusions under 2 CFR part 180.

Records come from many agencies. Each record shows the excluding agency, the exclusion type, the dates, and any cross-references to related names. The exclusion types you will see are Ineligible (Proceedings Pending), Ineligible (Proceedings Completed), Prohibition/Restriction and Voluntary Exclusion. HHS-OIG exclusions are among the records reported into SAM.gov, alongside actions from agencies such as the Department of Defense and the Environmental Protection Agency.

What happened to EPLS

Before SAM.gov, the government-wide list of excluded parties lived in the Excluded Parties List System, or EPLS. In 2012 EPLS was retired and its records and search moved into SAM.gov. Some regulations and older policies still say "EPLS," including 42 CFR 455.436 for state Medicaid agencies. In practice, an EPLS search today means searching the exclusion records in SAM.gov.

Side by side

Question	OIG LEIE	SAM.gov exclusions	OFAC SDN list
Who publishes it	HHS Office of Inspector General	General Services Administration, with records from many agencies	US Treasury, Office of Foreign Assets Control
What a listing means	No federal health care program payment for items or services the party furnishes, orders or prescribes	Barred from federal contracts, subcontracts and many kinds of federal assistance	Property blocked; US persons generally prohibited from dealing with the party
Who usually checks it	Providers, health plans, state Medicaid agencies, health care vendors	Contracting officers, prime contractors, grant recipients, health care compliance teams	Banks, payment companies, exporters, screening firms, any US business vetting a counterparty
How often it changes	Monthly	As agencies enter records	Whenever OFAC adds or removes names
Where to confirm a match	exclusions.oig.hhs.gov, with SSN or EIN	sam.gov, using the record's details and cross-references	sanctionssearch.ofac.treas.gov, comparing date of birth, nationality and addresses

Why health care organizations check both

If SAM.gov already includes HHS-OIG exclusions, it is fair to ask why anyone checks the LEIE separately. There are three practical reasons.

First, the LEIE is OIG's own list, published on OIG's own schedule. Checking it directly means you are looking at the source, with the fields OIG publishes, and you can use OIG's SSN and EIN verification to confirm a match.

Second, SAM.gov covers exclusions that the LEIE does not. A billing vendor debarred by another agency for procurement fraud may not appear on the LEIE at all. If that vendor works on your federal health care claims, or on a federal grant you hold, you want to know.

Third, the rules name both. State Medicaid agencies must check their enrolled providers against the LEIE and the federal exclusion records (the old EPLS, now SAM.gov) no less frequently than monthly under 42 CFR 455.436, and many pass the same expectation to the providers they enroll. Payer contracts and compliance program guidance often name both as well.

Why prime contractors check both

For federal contractors, SAM.gov is the required check. FAR 9.405 requires contracting officers to check SAM.gov exclusions before awarding a contract, and the FAR clause on subcontracting (52.209-6) tells prime contractors not to subcontract with excluded parties above a set threshold unless there is a compelling reason, and then only after notifying the contracting officer. Primes that hold health care contracts, or that subcontract to health care vendors, add the LEIE because SAM.gov is not built around health care program participation.

Where the OFAC SDN list fits

The OFAC Specially Designated Nationals and Blocked Persons List is a third list, and it answers a different question. It is not about whether the government will pay a party or contract with it. It is about whether a US person may deal with the party at all.

OFAC lists people, companies, vessels and aircraft whose property is blocked under US sanctions programs, such as country programs and counter-terrorism programs. US persons are generally prohibited from dealing with them, and OFAC liability does not depend on whether you knew. That is why banks, payment companies and screening firms check it, and why a vendor vetting program usually checks it alongside the two exclusion lists.

The SDN list also publishes aliases, and a careful search covers them. Our tool searches the SDN list and its aliases. It does not cover OFAC's other sanctions lists, such as the sectoral sanctions list; Treasury's own Sanctions List Search covers those. The OFAC search page runs the SDN list on its own.

A match on any list is a possible match

None of these lists gives you a reliable unique identifier for every record, so any name search returns possible matches. Confirm each one on the official site before acting on it: compare the date of birth, address, NPI, EIN or other details the record holds. Spelling also varies across sources, which is a hard problem in its own right. Our public-records search and screening work covers how fuzzy name search finds the right person when the spelling differs, without flooding reviewers with false matches.

Check all three in one search

Our free exclusion check searches the OIG LEIE, SAM.gov exclusions and the OFAC SDN list in one pass, for up to 25 names. Every result shows the file date it was checked against, and you can have the full report sent by email. It does not cover state Medicaid lists; we explain those in State Medicaid exclusion lists.

Talk to us

If you screen vendors, staff or applicants as part of your product or your operations, we build that screening into the workflow itself: scheduled runs, match review, confirmation records and an audit trail. Contact us and tell us which lists you check today and how.