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OIG Exclusion Database

Should a practice check the LEIE database (OIG Exclusions Database) for every vendor in their accounts payable file?

I would because you are paying the vendors with funds that come indirectly from the Medicare program. I have done this for a number of entities, and you would be surprised how people end up on the LEIE database. You will also want to check the SAM (System for Award Management) list under Government Services Administration’s list of Excluded Parties List System (GSA-EPLS). There is sometimes flow between these lists. 

For example, we had a vendor who made measurement tools that ended up being placed on the SAM list, and therefore they got excluded. We had to cease doing business with them, which was problematic because that vendor was a full-source vendor. This caused a screeching halt in certain critical technical programs. 

You will want to screen all your vendors just as you do with individuals during the hiring process. For new vendors, you will need to ask them about their exclusion status and screen them upfront before you establish a relationship with them. Many companies have made checking the exclusion list part of the process for setting up the company in the accounts payable system.

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