OIG Screening Calendar: The Monthly Compliance Routine (42 CFR § 1001.1901)
Executive Summary
Exclusion screening is a core compliance responsibility for healthcare providers participating in federal healthcare programs. Under 42 CFR § 1001.1901, no payment may be made for items or services furnished, ordered, or prescribed by excluded individuals or entities. For small practices, this means that employees, contractors, and vendors connected to federal claims must be monitored to prevent non-payable claims.
A structured OIG screening calendar helps practices perform screening activities consistently, document diligence, and reduce the risk of enforcement actions. This article explains how small practices can design and maintain a practical OIG screening calendar, supported by regulatory analysis, a real-world case example, a self-audit checklist, common pitfalls, and best practices.
Introduction
Small healthcare practices often operate with limited administrative resources while managing complex regulatory obligations. Compliance tasks such as exclusion screening are sometimes treated as one-time onboarding steps rather than ongoing responsibilities. However, exclusion status can change over time, and claims associated with excluded individuals may become non-payable even when the practice was unaware of the exclusion.
An OIG screening calendar provides a predictable, repeatable framework that embeds exclusion checks into routine operations. By scheduling screenings on a recurring basis and documenting results, practices can demonstrate reasonable diligence during audits and investigations.
Regulatory Breakdown
42 CFR § 1001.1901 – Effect of Exclusion
42 CFR § 1001.1901 establishes the scope and effect of exclusion from participation in federal healthcare programs. The regulation provides that:
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Exclusion applies to Medicare, Medicaid, and all other federal healthcare programs.
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No payment may be made for any item or service furnished by an excluded individual or entity after the effective date of exclusion.
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Payment is also prohibited for items or services furnished at the medical direction of, or on the prescription of, an excluded physician or authorized individual when the furnishing party knew or had reason to know of the exclusion.
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Excluded individuals may not submit claims or take assignment of claims during the exclusion period.
This prohibition applies regardless of whether the excluded individual performs clinical or administrative functions when their work is connected to federally reimbursed services.
Screening Frequency: Regulatory Requirement vs. Compliance Practice
The regulation does not specify a required screening frequency. However:
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The OIG updates the LEIE database monthly.
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Many auditors and surveyors expect screening practices to align with the availability of updated exclusion data.
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Monthly screening is therefore widely treated as a best practice, not a regulatory mandate.
A screening calendar allows practices to adopt a consistent approach that aligns with audit expectations without misrepresenting regulatory requirements.
Why a Screening Calendar Matters
Without a structured calendar, exclusion screening may be performed inconsistently or forgotten entirely. A documented schedule helps ensure that:
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Screenings occur regularly
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Results are logged and retained
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Follow-up actions are documented
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Leadership oversight is demonstrated
These elements are frequently reviewed during audits and investigations.
Case Study: Missed Re-Screening
A small family practice hired a part-time office assistant who supported scheduling and billing. The assistant was screened against the OIG LEIE at hire, but the practice did not perform recurring screenings.
During a Medicaid audit, surveyors determined that the assistant had been excluded several months after hire. Because the practice lacked a screening calendar and documentation of ongoing checks, claims associated with the assistant’s work were reviewed and repayment obligations followed.
Key Takeaway
A simple screening calendar could have identified the exclusion earlier and reduced financial exposure.
Self-Audit Checklist: OIG Screening Calendar Effectiveness
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Pre-Engagement Screening
Confirm screening of employees, contractors, and vendors before engagement. -
Recurring Screening Schedule
Verify that screenings occur on a consistent, documented schedule. -
Documentation Logs
Ensure logs include names, dates, reviewer initials, and results. -
Vendor Coverage
Confirm that billing services, staffing agencies, and other vendors are included. -
Flag Resolution
Verify that potential matches are investigated and resolved promptly. -
Record Retention
Retain screening documentation consistent with federal retention standards. -
Leadership Review
Confirm documented oversight by owners or management.
Common Pitfalls and How to Avoid Them
Screening Only at Hire
Avoidance: Use a recurring calendar rather than one-time checks.
Incomplete Documentation
Avoidance: Record each screening with dates and outcomes.
Excluding Contractors or Vendors
Avoidance: Include all individuals and entities connected to claims.
Delayed Follow-Up
Avoidance: Suspend federally connected duties until exclusion status is verified.
Assuming Small Practices Are Not Audited
Avoidance: Recognize that enforcement applies regardless of practice size.
Best Practices for Building a Screening Calendar
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Align screenings with payroll cycles or monthly administrative reviews
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Use OIG’s free LEIE search tools or downloadable database
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Centralize screening logs for easy retrieval
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Assign clear responsibility for screening tasks
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Conduct periodic internal reviews of calendar adherence
These practices help ensure screenings are consistent, defensible, and sustainable.
Building a Culture of Compliance
A screening calendar is most effective when supported by a broader compliance culture. Leadership involvement, staff training, and transparency reinforce the importance of exclusion screening and documentation.
When compliance tasks are treated as routine operational activities rather than exceptional burdens, consistency improves and risk decreases.
Conclusion
Under 42 CFR § 1001.1901, claims associated with excluded individuals are not payable, creating significant financial and enforcement risk for small practices. While the regulation does not mandate a specific screening frequency, a structured OIG screening calendar is a widely recognized best practice that supports defensible compliance.
By implementing a recurring screening schedule, documenting results, and maintaining oversight, small practices can reduce risk, demonstrate diligence, and protect themselves from avoidable enforcement actions.
Compliance should be a living process. By leveraging a regulatory tool, your practice can maintain real-time oversight of requirements, identify vulnerabilities before they escalate, and demonstrate to both patients and payers that compliance is built into your culture.