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Understanding Healthcare Exclusion Lists: What They Are, Why They Exist & How Someone Gets Listed

Healthcare exclusion lists identify individuals and entities barred from participating in federal healthcare programs. Learn what they are, why they exist, and how exclusions happen.

What Is an Exclusion List?

In healthcare, an exclusion list is a government-maintained database of individuals and entities that are prohibited from participating in federal healthcare programs such as:

  • Medicare

  • Medicaid

  • TRICARE

  • Other federally funded healthcare programs

The most well-known federal exclusion list is maintained by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) and is called:

The List of Excluded Individuals and Entities (LEIE)

In addition to the federal list, each state may maintain its own Medicaid exclusion list.

Why Do Exclusion Lists Exist?

Exclusion lists are designed to protect:

  • Patients

  • Federal healthcare funds

  • Program integrity

They prevent individuals and organizations that have engaged in fraud, abuse, or serious misconduct from continuing to participate in federally funded healthcare programs.

The goal is to reduce:

  • Fraudulent billing

  • Patient harm

  • Financial abuse of government programs

  • Ethical violations

What Does It Mean to Be “Excluded”?

If a person or entity is excluded:

  • They cannot bill federal healthcare programs

  • They cannot provide services reimbursed by federal programs

  • They cannot work for organizations that receive federal healthcare payments (even indirectly)

This applies to:

  • Owners

  • Providers

  • Managers

  • Clinical staff

  • Administrative employees

  • Vendors

If any part of an excluded individual’s compensation is connected to federal healthcare dollars, it may create liability.

What Does Someone Have to Do to Get on an Exclusion List?

Exclusions typically result from serious violations of law or regulatory requirements.

There are two main categories:

1. Mandatory Exclusions

Federal law requires exclusion for certain offenses, including:

  • Convictions related to Medicare or Medicaid fraud

  • Patient abuse or neglect

  • Felony convictions related to healthcare fraud

  • Felony convictions related to controlled substances

These exclusions are automatic upon conviction.

2. Permissive Exclusions

The OIG may choose to exclude individuals for:

  • Misdemeanor healthcare fraud

  • License revocation or suspension

  • Kickback violations

  • Submission of false claims

  • Obstruction of an investigation

  • Failure to repay overpayments

  • Defaulting on healthcare-related student loans

Permissive exclusions are determined based on severity and risk to federal programs.

How Long Does an Exclusion Last?

The length of exclusion depends on the offense.

  • Mandatory exclusions typically last a minimum of 5 years

  • More serious offenses may result in longer periods

  • Some exclusions can be indefinite

Reinstatement is not automatic, the excluded individual must apply for reinstatement after the exclusion period ends.

Why Exclusion Screening Is Required

Healthcare organizations are expected to ensure they do not:

  • Employ excluded individuals

  • Contract with excluded vendors

  • Bill for services involving excluded persons

If an organization hires or contracts with someone on the exclusion list and bills federal programs, it may face:

  • Civil monetary penalties

  • Repayment obligations

  • False Claims Act liability

  • Corporate integrity agreements

Even if the organization was unaware of the exclusion, liability can still apply.

How Often Should Organizations Screen?

Best practice (and industry standard) is to:

  • Screen all employees and vendors monthly

  • Check both federal and applicable state exclusion lists

  • Document all screenings

Exclusion monitoring is a core element of an effective corporate compliance program.

What Regulators Look For

During audits or investigations, regulators may request:

  • Documentation of monthly exclusion screenings

  • A list of employees and vendors screened

  • Evidence of actions taken if a match is found

Failure to conduct regular screening is a common compliance gap.

What Happens If You Discover an Excluded Individual?

If a match is identified:

  1. Confirm the match (verify identifiers carefully)

  2. Immediately stop billing for services involving that individual

  3. Investigate the scope of involvement

  4. Consult compliance and legal counsel

  5. Evaluate potential overpayment repayment obligations

Prompt corrective action is critical.

Not sure if your organization is screening properly?
Review your exclusion monitoring process and documentation procedures.

Last reviewed: February 2026