Healthcare Background Checks: OIG, SAM & FACIS Explained
Healthcare screening is different. Beyond the criminal and identity checks every employer runs, healthcare organizations face a federal mandate with real teeth: hiring or retaining anyone excluded from federal healthcare programs can trigger civil monetary penalties and repayment of every claim that person touched. Here’s what a compliant healthcare screening program looks like.
The exclusion lists you must check
OIG LEIE
The Office of Inspector General’s List of Excluded Individuals and Entities names people barred from participation in Medicare, Medicaid, and other federal health programs — typically for fraud convictions, patient abuse, or license revocations. Employing an excluded person in any role that touches federally funded care, even indirectly, exposes you to penalties.
GSA / SAM.gov
The System for Award Management consolidates parties debarred from federal contracts and programs government-wide. Healthcare organizations check SAM alongside the LEIE because the lists overlap imperfectly.
State Medicaid exclusion lists
Most states maintain their own Medicaid exclusion lists, and a person can appear on a state list without appearing on the federal ones. Multi-state systems need to check every state where they operate.
What is FACIS?
FACIS — Fraud and Abuse Control Information System — is the healthcare industry’s standard aggregated sanctions search, combining thousands of sources: OIG, SAM, state exclusion lists, state licensing board disciplinary actions, DEA/FDA actions, and more. It comes in levels:
| Level | Scope | Typical use |
|---|---|---|
| Level 1 | Minimum federal requirement: OIG, SAM + core sources | Baseline compliance |
| Level 2 | Level 1 + expanded state sources | Mid-tier programs |
| Level 3 | The most comprehensive: all jurisdictions’ available sanction, exclusion, and disciplinary sources | Standard of care for hospitals and health systems |
We include FACIS III capability in our criminal records lineup, alongside the license verifications that catch problems sanctions lists miss.
Screening once isn’t enough: monthly monitoring
The OIG advises checking exclusion lists monthly, because exclusions happen continuously — a nurse in good standing at hire can be excluded mid-employment. A compliant program pairs pre-hire screening with ongoing monthly rescreening of the active workforce. (This is the strongest argument for a provider with batch processing and no per-order minimums — monthly re-checks shouldn’t require renegotiating your contract.)
The rest of the healthcare screen
Exclusion checks sit on top of the standard package, not in place of it:
- Criminal records — county, state, federal, and the 50-state sex offender registry; many states mandate specific checks for patient-facing roles (what shows up)
- License and certification verification — primary-source verification of RN, MD, CNA, and allied health credentials, including disciplinary history
- Education and employment verification — degree mills are a real problem in clinical hiring
- Drug testing and occupational health — panels, physicals, TB testing, and titers through our HIPAA-certified occupational health services, scheduled at collection sites near each candidate
- I-9 and identity — SSN trace as the foundation
Speed matters here too: nursing and allied-health hiring is competitive, and most of our reports return in 8–24 hours, so compliance doesn’t cost you candidates.
Build your healthcare screening program
We screen for hospitals, home health agencies, long-term care, staffing firms, and practices of every size — FACIS III, monthly exclusion monitoring, license verification, and occupational health in one platform, with transparent per-report pricing and no contracts. Create your account free or talk to a PBSA-certified specialist at 1-800-935-8537.
This article is general information, not legal advice. Consult your compliance counsel about the requirements that apply to your organization.
