How to Run OIG Exclusion Checks for Tennessee Home Care Agencies

What Is the OIG Exclusion List?

The Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) is a federal database maintained by the U.S. Department of Health and Human Services. It contains the names of individuals and organizations that have been excluded from participating in federally funded healthcare programs — including Medicare and Medicaid.

If someone on the OIG exclusion list provides services to a Medicaid beneficiary, the agency employing them can be required to refund all payments received for those services — even if the agency had no knowledge of the exclusion. The financial exposure is significant, and TennCare surveyors look for this specifically during audits.

Why TennCare Requires Monthly OIG Checks

Tennessee's TennCare program — the state's Medicaid program — requires all home care providers, including Home Health Agencies (HHAs), Developmental Service Providers (DSPs), and personal care agencies, to screen employees against federal exclusion databases before employment and on a monthly basis thereafter.

This requirement exists because exclusions happen to existing employees too. An employee who was clean at hire may be excluded later due to a fraud conviction, license revocation, or other disqualifying event. Monthly checks catch these cases before they become costly compliance violations.

During a TennCare survey, compliance officers will ask for documentation proving you ran these checks — typically in the form of a dated report showing each employee was verified against the OIG database for each month in the audit period.

How to Run OIG Checks Manually

Here's the process most agencies use today — and why it breaks down at scale:

Step 1: Download the OIG Exclusion Database

Go to oig.hhs.gov and download the full LEIE data file. OIG updates this file monthly, typically on the last business day of each month. The file is large — over 83,000 records — and comes in CSV format.

Step 2: Check Each Employee Against the File

You'll need to search for each employee by first name, last name, and date of birth. Searching by name alone is not sufficient because common names produce false positives. Using date of birth significantly improves matching accuracy.

Manually, this means opening the CSV in Excel and running a VLOOKUP or filter for each employee — one at a time. For an agency with 15 employees, this takes 30–60 minutes every month. For agencies with 50+ employees, it becomes a half-day project.

Step 3: Document Your Results

TennCare surveyors don't just want to know you ran the checks — they want documentation. This means keeping a dated record showing:

• Which employees were checked
• The date the check was performed
• Which version of the OIG database was used
• The result for each employee (clear or flagged)

Most agencies keep this in a spreadsheet, which creates version control problems and is difficult to present to surveyors on short notice.

The Three Registries Tennessee Agencies Must Check

OIG is just one of three registries TennCare compliance requires. A complete monthly check includes:

• OIG LEIE — federal exclusions from HHS (83,000+ records, updated monthly)
• SAM.gov — federal System for Award Management exclusions (167,000+ records)
• TennCare TTPL — Tennessee's own Terminated Provider List, maintained by TennCare's Program Integrity division

Each database must be checked separately, and documentation for each must be maintained. Agencies that only check OIG but miss SAM.gov or TTPL are still at risk during a survey.

How to Automate OIG and Registry Checks

Manual checks work for very small agencies, but they don't scale — and the documentation burden alone creates significant compliance risk. Automated tools solve both problems.

ClearCheckTN was built specifically for Tennessee home care and DSP agencies. Upload your employee list as a CSV and the platform automatically checks every employee against OIG LEIE, SAM.gov, and TennCare TTPL simultaneously. Results come back in seconds, with a survey-ready PDF report documenting which database version was used, the date of the check, and the result for each employee.

Monthly reminders ensure you never miss a check cycle, and the audit log means you always have documentation ready — even if a surveyor shows up unannounced.

What Happens If You Miss a Check

If a TennCare survey finds that you employed an excluded individual — even unknowingly — the consequences can include:

• Repayment of all Medicaid claims submitted during the period of exclusion
• Civil monetary penalties of up to $20,000 per claim
• Exclusion of your agency from the TennCare program
• Referral to the OIG for federal investigation

The monthly check requirement exists specifically to prevent these situations. Documented, consistent compliance is the only reliable protection.

Getting Started

If you're currently running manual checks, the fastest way to get compliant and stay compliant is to automate the process. ClearCheckTN offers a Starter plan at $149/month for agencies with up to 5 employees — with OIG, SAM.gov, and TTPL checks included, plus monthly PDF reports ready for surveyors.

Setup takes less than 10 minutes. Upload your employee list, run your first check, and download your compliance report — all before your next cup of coffee.

Frequently Asked Questions

How often does OIG update the exclusion list?

OIG updates the LEIE on the last business day of each month. TennCare compliance requires monthly checks against the current version of the database.

Is checking OIG enough, or do I need to check SAM.gov and TTPL too?

TennCare compliance requires all three — OIG LEIE, SAM.gov, and the TennCare Terminated Provider List. Checking only one database leaves gaps that surveyors will find.

What information do I need to check an employee?

First name, last name, and date of birth. Using all three reduces false positives and false negatives significantly compared to name-only searches.

How long do I need to keep compliance records?

TennCare generally requires providers to maintain compliance records for a minimum of 5 years. Survey-ready PDF reports with source file documentation are the safest format.

What if an employee shows up on the OIG list?

Do not allow them to provide services to Medicaid beneficiaries until the match is fully investigated. Many matches are false positives due to common names — verify by date of birth and other identifiers before taking action. Consult your compliance officer or legal counsel if a match is confirmed.