For every healthcare organization and provider, it is critical to understand the consequences of employing or contracting with a sanctioned individual or entity or one which is excluded from participation in federally-funded health care programs. Otherwise, they can face significant risks from financial, compliance, and patient safety standpoints. To avoid this and ensure compliance and patient safety, healthcare organizations need to screen two federal sources for exclusions, as well as State Medicaid exclusion lists.
The two major federal sources that need to be continuously monitored are the HHS Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE) and the U.S. General Services Administration’s System for Award Management (SAM). The System for Award Management exclusion list includes actions taken by multiple federal agencies while LEIE consists of exclusion actions taken by the HHS OIG.
What Is SAM.gov?
The System for Award Management is an official website of the U.S. government, managed by the General Services Administration (GSA). SAM.gov is free for entities to:
- Register to do business with the U.S. government,
- Update or renew their entity registration,
- Check the status of an entity registration, and
- Search for entity registration and exclusion records.
The SAM.gov database is formerly known as the Government Services Administration’s (GSA) Excluded Parties List System (EPLS). The EPLS was established in 2007 to allow federal agencies to check that potential vendors are eligible for federal contracts. The EPLS database could be used to determine if vendors were suspended, debarred, or otherwise disqualified from federal contracts or receiving federal funds.
In 2012, GSA transferred data from the EPLS to a more comprehensive system called the System for Award Management. The SAM database has all of the information that was previously in the EPLS, but there are some differences in how that information is organized and some of the terminology is different. Still, the purpose of the System for Award Management exclusion list is no different from the EPLS, which is to provide a list of individuals and entities debarred from contracting with the federal government.Use this comprehensive guide to find out how to avoid paying costly penalties and risking financial misconduct while maintaining effective healthcare compliance.
Changes Introduced to the System for Award Management Exclusion List
In May 2021, SAM.gov introduced a new user interface and a reorganization of the site. Some of the changes made in this process are:
- A single user URL and login for all functions currently in SAM.gov,
- A single personalized user Workspace based on user roles and the entity registrations,
- Landing pages with help specific to entity registrations, exclusions, and entity reporting,
- Service Contract Reporting (SCR) and Bio-Preferred reporting access from the entity’s Workspace,
- System account functionalities for non-federal users,
- Login requirement to search entity registration data,
- Optional identity verification for entity administrators which is not required until 2022,
- Streamlined search filter functionality,
- Search for contract opportunities,
- Search for U.S. Department of labor wage rate determinations, and
- Current SAM.gov registration functions.
These changes were incorporated so that the System for Award Management exclusion list is more than a registration system. They are based on customer-focused functionality and aim to improve the overall experience for site visitors and ensure a streamlined advanced search experience.
Importance of Screening the System for Award Management Exclusion List
While SAM.gov contains a list of contractors and entities approved to work with the federal government, it also includes a list of contractors and entities excluded from working with the government. However, the System for Award Management exclusion list does not provide license information or National Provider Identifier (NPI) records of those on the exclusion list. Such information is necessary to verify that search results actually match the candidates screened. As a result, if employers find a candidate or contractor marked as excluded, they should contact the federal agency to verify the results.
Entities and individuals found on the System for Award Management exclusion list can pose serious legal and reputational risks to healthcare organizations that hire them. Therefore, it is strongly advised to check SAM.gov at least monthly. However, the System for Award Management exclusion list is insufficient by itself, and healthcare organizations need to conduct regular screening of LEIE. Furthermore, in addition to LEIE and SAM.gov, 43 states and jurisdictions maintain their own Medicaid exclusion lists that also need to be monitored.
To maintain healthcare compliance, the best practice is to search all the exclusion lists in order to obtain the most comprehensive information on excluded, sanctioned, and debarred individuals and entities. However, checking all of these databases can be challenging and time-consuming and create significant administrative burdens for healthcare organizations. However, to simplify navigating different databases, checking the System for Award Management exclusion list, and verifying information with other federal agencies, healthcare organizations can outsource the entire process and use exclusion screening software. As a result, they can avoid a risk of non-compliance during the screening process, prevent OIG penalties, and reduce risks to patients, staff, and the organization’s reputation.