LEIE vs SAM.gov: the two federal exclusion lists, compared
Every exclusion-screening rule in health care names two federal databases: the OIG's List of Excluded Individuals and Entities (LEIE) and the System for Award Management (SAM.gov). They are often spoken of as one check. They are not: different agencies, different legal bases, different scope, different fields, different schedules. Here is what each one is, how they overlap, and what falls between them.
Live from the published RosterProof dataset, refreshed weekly.
Side by side
| OIG LEIE | SAM.gov exclusions | |
|---|---|---|
| Publisher | HHS Office of Inspector General | General Services Administration, on behalf of every federal agency |
| Legal basis | Exclusion authorities in the Social Security Act (§1128 and §1156): mandatory exclusions for program-related crimes, patient abuse and felony convictions; permissive exclusions for license revocations, defaults and other grounds | Government-wide debarment and suspension under the procurement and non-procurement rules (FAR subpart 9.4, 2 CFR 180) plus statutory exclusions reported by agencies, including OIG's |
| Who appears | Individuals and entities barred from payment by Medicare, Medicaid and all other federal health care programs | Anyone any federal agency has excluded from federal contracts, grants or benefits: contractors, individuals, health care providers and others |
| Effect of an entry | No federal health care program payment for items or services furnished, ordered or prescribed by the excluded party; employer liable for civil monetary penalties | Ineligible for federal awards and, for OIG-reported entries, the same health program consequences; the SAM record names the excluding agency and the exclusion type |
| Identifiers published | Name, general (business) name, specialty, address, exclusion type (statute), exclusion date, reinstatement date, NPI where known, DOB and SSN/EIN for verification only | Name, classification (individual / firm / etc.), exclusion type and program, excluding agency, activation and termination dates, addresses, DUNS/UEI and CAGE for entities |
| Updates | Monthly database file plus a monthly supplement of additions and reinstatements | Continuous; a public extract is published daily |
| Confirming a match | OIG Online Search accepts SSN or EIN to verify a name match definitively | The SAM record itself; for entities, the UEI |
How they overlap
OIG reports its exclusions to SAM.gov, so an LEIE entry usually has a SAM counterpart naming "HHS-OIG" as the excluding agency. The reverse is far from true: SAM holds roughly twice as many active exclusion records as the LEIE, most of them from agencies that have nothing to do with health care. Checking SAM alone therefore finds more people but with far more noise for a provider roster; checking the LEIE alone misses exclusions that other agencies imposed. The two files also update on different cycles and publish different identifiers, which is why 42 CFR 455.436 asks state Medicaid programs to check both every month rather than either one.
In RosterProof the two are loaded as separate sources (SOURCE_ID = 'LEIE' and 'SAM') with
EXCLUSION_AUTHORITY carrying the excluding agency on SAM records, so a screen can treat them as two checks while running them as one.
What neither one covers
State Medicaid agencies exclude and terminate providers on their own authority: license actions, program-integrity findings, Medicaid fraud-unit referrals, terminations for cause. Those actions are supposed to flow to OIG, and many do, but across every state list RosterProof loads about half of the active records have no LEIE counterpart, and in some states more than 90% (the federal gap, measured per state). Under ACA §6501 a termination for cause in one state is grounds for termination in every other, so these records matter everywhere. The state lists are the third check, and the one most often skipped.
Drug and device sponsors have a fourth and fifth: the FDA debarment list and the clinical-investigator disqualification list (life sciences screening). And a Medicare opt-out affidavit, which some screening tools surface next to exclusions, is a status rather than a sanction and should never be treated as a hit.
Checking all of them at once
The point of a unified dataset is that the distinction stops costing effort. Screen my providers checks a pasted or uploaded roster against the LEIE, SAM.gov, the FDA lists and every loaded state list in one pass, and tells you which list each hit came from. The same data is a join in Snowflake, a call to the API, or a weekly download. Step-by-step: how to check whether a provider is excluded.