Understanding OIG SAM Compliance

Posted by Joe Stefansky on June 13, 2025 in Exclusion Screening, SAM,

Healthcare organizations must screen against the OIG SAM databases to ensure they do not work with individuals or entities excluded from federal healthcare programs like Medicare and Medicaid. The Office of Inspector General (OIG) maintains the List of Excluded Individuals/Entities (LEIE), updated monthly, while the System for Award Management (SAM) tracks exclusions from federal contracts, updated annually. Staying compliant protects organizations from operational and reputational risks.

Recent 2025 Updates

In 2025, Home | SAM.gov integrated subaward reporting after FSRS.gov’s retirement, centralizing data and increasing vetting needs for subrecipients.

Additionally, clarifications specify that sub-awardees may only need a Unique Entity ID (UEI) unless applying for federal awards, shifting due diligence to prime contractors. New data privacy laws also emphasize compliance with regulations like the Privacy Act of 1974, with stricter enforcement this year.

Benefits of Compliance Software

Using automated OIG SAM software simplifies screening by updating with the latest exclusion data, reducing manual errors, and providing audit-ready reports. This allows compliance teams to focus on patient care and strategic goals, addressing challenges like resource constraints, where over 50% of teams struggle with manual processes

Why It Matters

With the OIG excluding around 3,000 entities yearly, regular OIG SAM checks are critical. Software solutions and best practices, like monthly screenings and workflow integration, help organizations stay compliant efficiently.

    OIG SAM Compliance: Navigating 2025 Updates and Best Practices for Healthcare Organizations

    In the dynamic and highly regulated healthcare sector, maintaining compliance with federal regulations is critical to ensure operational integrity and avoid potential risks. A cornerstone of this effort is OIG SAM compliance, which involves screening against the Office of Inspector General’s (OIG) List of Excluded Individuals/Entities (LEIE) and the System for Award Management (SAM) databases. These databases identify individuals and entities barred from participating in federal healthcare programs, such as Medicare and Medicaid, due to issues like fraud or patient abuse. As we move through 2025, recent updates and ongoing challenges in OIG SAM compliance underscore the importance of adopting advanced tools and best practices to streamline processes and stay ahead of regulatory requirements.

    In the dynamic and highly regulated healthcare sector, maintaining compliance with federal regulations is critical— a cornerstone of this effort is OIG SAM compliance.

    The Importance of OIG SAM Compliance

    OIG SAM compliance is a vital safeguard for healthcare organizations, ensuring they do not inadvertently employ or contract with excluded individuals or entities. The OIG’s LEIE, updated monthly, lists those excluded from federal healthcare programs, while SAM, updated annually, tracks exclusions from federal contracts and grants. Non-compliance can lead to significant operational disruptions and reputational damage, making regular screening a non-negotiable part of compliance programs. With the OIG excluding approximately 3,000 individuals and entities each year, proactive OIG SAM checks are essential to maintain regulatory adherence and protect organizational integrity.

    Recent Developments in OIG SAM Compliance

    The year 2025 has brought several notable updates to OIG SAM compliance, reflecting the evolving nature of healthcare regulations. These developments highlight the need for organizations to adapt their compliance strategies to stay current:

    • Integration of Subaward Reporting into Home | SAM.gov : On March 8, 2025, Home | SAM.gov integrated subaward reporting functions following the retirement of FSRS.gov. This centralization of subaward data streamlines reporting but increases the need for thorough vetting of subrecipients, particularly for sensitive contracts. Healthcare organizations must ensure their OIG SAM screening processes account for these new data requirements to maintain compliance.
    • Clarifications on SAM Registration Requirements: Recent guidance has clarified that sub-awardees may only need a Unique Entity ID (UEI) rather than full SAM registration unless they are directly applying for federal awards. This shift places additional due diligence responsibilities on prime contractors, who must verify the compliance status of their subcontractors during OIG SAM screenings.
    • Increased Emphasis on Data Privacy Compliance: New state and federal data privacy laws in 2025 have heightened the focus on compliance with regulations such as the Privacy Act of 1974 and the Fair Credit Reporting Act (FCRA). With stricter enforcement this year, healthcare organizations must ensure their OIG SAM compliance processes align with these privacy standards to protect sensitive data and avoid regulatory scrutiny.
    • OIG Exclusion List Updates: The OIG continues to update its LEIE monthly, with recent additions in March 2025 including entities like Assure Holdings, Assure Neuromonitoring, and Alex De Jesus, MD, due to violations involving improper remuneration and false claims. These updates emphasize the importance of regular OIG SAM screenings to identify excluded parties promptly and prevent compliance lapses.

    Challenges in Maintaining OIG SAM Compliance

    Healthcare organizations face several challenges in ensuring effective OIG SAM compliance, particularly in 2025. These obstacles highlight the limitations of manual processes and the need for automated solutions:

    • Frequent Database Updates: The OIG’s LEIE is updated monthly, necessitating regular screenings to ensure no excluded individuals or entities are engaged. While Home | SAM.gov is updated annually, experts recommend screening at a similar cadence, especially during onboarding, to catch any status changes.
    • Resource Constraints: Over 50% of healthcare compliance teams report resource constraints as a significant barrier, making manual OIG SAM verification labor-intensive and prone to oversight. This challenge is particularly acute for organizations with large workforces or extensive vendor networks.
    • Name Variations and False Positives: OIG screenings often encounter issues with name variations, leading to false positives that require manual identity verification. Similarly, SAM screenings can be complicated by overlapping data and duplicate entries, increasing the risk of errors and adding to the compliance workload.

    Compliance ChallengeDescriptionImpactFrequent UpdatesOIG LEIE updated monthly, SAM annuallyRequires regular screenings to stay currentResource ConstraintsOver 50% of teams lack sufficient resourcesIncreases risk of manual errors and delaysName VariationsFalse positives due to similar namesAdds manual verification workloadData OverlapDuplicate entries in SAM databaseCauses confusion and screening inefficiencies.

    The Role of Compliance Software in OIG SAM Screening

    To overcome these challenges, healthcare organizations are increasingly adopting advanced OIG SAM compliance software. These tools offer significant advantages over manual processes, enhancing efficiency and accuracy:

    • Automated Screening: Compliance software automates OIG SAM checks, integrating with HR systems and vendor management platforms to perform screenings during onboarding and ongoing operations. This reduces the risk of human error and ensures comprehensive coverage .
    • Real-Time Data Updates: Advanced tools sync with the latest OIG LEIE and Home | SAM.gov data, ensuring screenings are always based on current exclusion lists. This is critical given the monthly updates to the OIG list and annual updates to SAM .
    • Audit-Ready Documentation: Compliance software generates detailed audit trails, providing evidence of adherence to regulatory requirements. This documentation is invaluable during audits or investigations, demonstrating a commitment to OIG SAM compliance.
    • Operational Efficiency: By automating repetitive tasks, compliance tools free up resources, allowing compliance teams to focus on strategic priorities such as patient care and organizational growth. This is particularly beneficial for organizations facing resource constraints.

    Best Practices for OIG SAM Compliance in 2025

    To ensure robust OIG SAM compliance, healthcare organizations should implement the following best practices, informed by recent developments and industry recommendations:

    • Conduct Regular Screenings: Perform monthly checks against the OIG’s LEIE and schedule automated Home | SAM.gov searches at least annually, with additional checks during onboarding to catch any status changes.
    • Expand Screening Scope: Include additional databases, such as state Medicaid exclusion lists and the Office of Foreign Asset Control (OFAC) Sanctions List, to ensure comprehensive compliance .
    • Integrate with Workflows: Embed OIG SAM checks into HR, vendor onboarding, and contract execution processes to prevent non-compliant individuals or entities from being engaged.
    • Leverage Automation: Use compliance software to automate screenings, reduce false positives, and streamline remediation processes, improving efficiency and accuracy.
    • Perform Regular Audits: Conduct bi-annual internal audits to verify adherence to compliance policies and identify areas for improvement.
    • Develop a Remediation Plan: Establish a clear process for addressing potential matches, including verification using identifiers like Social Security Numbers or Dates of Birth, investigation, and corrective action, with thorough documentation for audits.
    • Incorporate Contract Clauses: Include exclusion-related clauses in contracts to outline responsibilities, termination rights, and corrective actions in case of non-compliance.

    Why OIG SAM Compliance Matters

    OIG SAM compliance is more than a regulatory obligation; it is a critical component of maintaining the integrity of federal healthcare programs and protecting organizational operations. With the OIG excluding around 3,000 individuals and entities annually, the risk of engaging an excluded party is significant. By staying informed about 2025 updates, such as the Home | SAM.gov subaward integration and heightened data privacy requirements, and adopting advanced compliance tools, healthcare organizations can mitigate risks and focus on delivering high-quality patient care.

    Conclusion

    As healthcare regulations continue to evolve in 2025, OIG SAM compliance remains a top priority for organizations seeking to operate ethically and efficiently. Recent developments, including the centralization of subaward reporting in Home | SAM.gov , clarifications on registration requirements, and increased data privacy enforcement, highlight the need for robust compliance frameworks. By implementing best practices and leveraging automated compliance software, healthcare providers can navigate the complexities of OIG SAM compliance with confidence, ensuring regulatory adherence while prioritizing their core mission of patient care.

    About Joe Stefansky

    About Joe Stefansky

    Joe Stefansky has a keen sense of business opportunities in complex problems, using technology to transform difficulty into efficiency. The CEO and founder of Streamline Verify specializes in solving compliance, legal and administrative issues through intuitively designed software that reduces costs and saves time.

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