Understanding the Differences Between OIG LEIE and GSA Exclusion Lists

Understanding the Differences Between OIG LEIE and GSA Exclusion Lists

May 23, 2024

Understanding the Differences Between OIG LEIE and GSA Exclusion Lists

Exclusion lists play a critical role in maintaining the integrity of various federal programs and safeguarding public funds. Two significant lists in this context are the OIG LEIE and the GSA Exclusion List. Understanding the differences between these two can help organizations remain compliant and avoid severe penalties.

What is the OIG LEIE?

The OIG LEIE, or the Office of Inspector General’s List of Excluded Individuals and Entities, is a comprehensive database managed by the U.S. Department of Health and Human Services (HHS). It identifies individuals and entities excluded from participating in federally funded healthcare programs due to fraudulent activities or other misconduct.

History and Background of OIG LEIE

The OIG LEIE was established to combat healthcare fraud and abuse, protecting federal healthcare programs like Medicare and Medicaid. Over the years, it has evolved to include a broader range of infractions and more sophisticated tracking and updating mechanisms.

Criteria for Inclusion in the OIG LEIE

Inclusion in the OIG LEIE typically results from severe violations, including Medicare or Medicaid fraud, patient abuse, felony convictions related to healthcare fraud, and license revocations. These infractions demonstrate a clear threat to the integrity of healthcare programs.

Implications of Being Listed on the OIG LEIE

Being listed on the OIG LEIE carries significant consequences. Excluded individuals and entities are barred from participating in all federally funded healthcare programs. This exclusion affects employment opportunities, business operations, and overall reputation within the healthcare industry.

What is the GSA Exclusion List?

The GSA Exclusion List, managed by the General Services Administration, is a broader federal exclusion list that identifies individuals and entities excluded from receiving federal contracts and grants. It ensures that federal funds are awarded only to responsible and ethical parties.

History and Background of GSA Exclusion List

The GSA Exclusion List originated as part of efforts to ensure the federal government only engages with reputable contractors and grant recipients. It has grown to include a wide range of violations and employs rigorous standards for inclusion and updates.

Criteria for Inclusion in the GSA Exclusion List

Individuals and entities can be placed on the GSA Exclusion List for a variety of reasons, including contract fraud, tax evasion, and failure to perform on federal contracts. These actions indicate a failure to adhere to the ethical and performance standards expected in federal dealings.

Implications of Being Listed on the GSA Exclusion List

Listing on the GSA Exclusion List has far-reaching consequences, such as disqualification from receiving federal contracts, subcontracts, and grants. This exclusion can severely limit business opportunities and tarnish professional reputations.

Key Differences Between OIG LEIE and GSA Exclusion Lists

While both lists serve to protect federal interests, they differ in scope and impact. The OIG LEIE is specific to healthcare programs, focusing on violations that compromise patient care and program integrity. The GSA Exclusion List covers a wider range of federal activities, ensuring all federal contractors and grantees meet high standards of conduct.

Overlap Between OIG LEIE and GSA Exclusion Lists

There are instances where individuals or entities may appear on both lists. This typically occurs when healthcare providers also engage in federal contracts outside of healthcare. Agencies coordinate to manage such overlaps, ensuring comprehensive enforcement of exclusion policies.

Compliance and Screening Practices

Regular screening against these exclusion lists is crucial for organizations to maintain compliance. Best practices include incorporating automated screening tools, conducting periodic manual reviews, and staying updated with the latest list modifications.

How to Check the OIG LEIE

To check the OIG LEIE, access the database through the HHS OIG website. Users can search by name or entity and verify the exclusion status. Interpreting the results requires careful attention to details like dates and specific violations listed.

How to Check the GSA Exclusion List

The GSA Exclusion List can be accessed via the System for Award Management (SAM) website. Similar to the OIG LEIE, searches can be performed by name or entity. Understanding the implications of listings is essential for making informed compliance decisions.

OIG SAM: An Integrated Approach

The OIG SAM, or System for Award Management, integrates various exclusion lists, including the OIG LEIE, into a single, comprehensive platform. This integration simplifies the process for organizations to conduct thorough exclusion screenings. By using OIG SAM, entities can efficiently verify the eligibility of individuals and businesses for federal contracts and grants, ensuring compliance across multiple federal programs. The OIG SAM platform provides a streamlined approach to access and interpret exclusion information, enhancing organizational due diligence and reducing the risk of inadvertently engaging with excluded parties.

Steps to Take if Listed

If an individual or entity finds themselves listed on either the OIG LEIE or GSA Exclusion List, immediate steps should be taken. Legal recourse may involve appealing the listing or demonstrating corrective actions. Rehabilitation programs and removal processes vary by the nature of the violation and the specific list.


Understanding the differences between the OIG LEIE and GSA Exclusion Lists is crucial for organizations and individuals involved in federal programs. Regular compliance checks, awareness of the criteria for exclusion, and proactive measures can help mitigate the risks associated with these lists.

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