Programmatic access terms — and what this data may never be used for.
These terms govern programmatic access to Fonteum's exclusion and sanction-list data through the REST API and the Model Context Protocol (MCP) server. They sit on top of the general Terms of Service; where the two conflict for API or MCP use, this page governs. Pilot and Enterprise agreements supersede both.
Last updated: 2026-06-21
1. What the data is
The API and MCP server expose aggregated, source-provenanced data derived from public federal and state registries — including the HHS-OIG List of Excluded Individuals and Entities (LEIE), the GSA SAM.gov exclusions registry, state Medicaid exclusion lists, and related program-integrity records. It is a billing and program-integrity monitoring product: it answers whether a provider, vendor, or billing entity is barred from federal health programs so that an organization does not submit claims for, or pay federal funds to, an excluded party. It handles public records only.
2. Prohibited uses (FCRA permissible-purpose firewall)
Fonteum is not a consumer reporting agency, and the data is nota “consumer report” under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (the “FCRA”). You may not use the data, the API, or the MCP server — in whole or in part, alone or combined with other data — for any FCRA permissible purpose, or to make, inform, or assist any eligibility decision about an individual. Prohibited uses include, without limitation:
- Employment — pre-employment or employee background screening, hiring, retention, promotion, reassignment, vetting of applicants or candidates, or any other employment-eligibility decision.
- Credit — any credit decision, credit eligibility, creditworthiness assessment, or underwriting of a loan or financial product.
- Insurance — underwriting, eligibility, or rating of an insurance policy for an individual.
- Housing — tenant screening or any rental, lease, or housing-eligibility decision.
- Professional licensing— determining an individual's eligibility for a license, certification, or government benefit, where used as a consumer report about that person.
The permitted use is the inverse: checking the providers, vendors, and contractors your organization bills federal programs for, or pays with federal funds, against exclusion and sanction lists — a billing and program-integrity control, not a judgment about an individual's fitness for a job, a loan, a policy, a home, or a license.
3. Enforcement & right to terminate
Compliance with §2 is a material condition of access. Fonteum reserves the right, at its sole discretion and without notice, to suspend or terminate any account, API key, or MCP credential that it reasonably believes is using the data for a prohibited purpose, and to refuse further service. This is in addition to every other remedy available under the general Terms of Service or an applicable signed agreement.
4. No warranty for prohibited uses
The data is provided “as is” for the permitted billing / program-integrity purpose only. Fonteum makes no representation that the data is suitable, accurate, complete, or lawful for any FCRA permissible purpose, and disclaims all liability arising from any prohibited use. A match is a pointer to a primary federal or state source to confirm — not an adverse-action determination about any person.
5. Relationship to the general Terms
The general Terms of Service — licensing scope, acceptable use, attribution, warranties, liability, termination, governing law — apply in full to API and MCP access. This page adds the API/MCP-specific prohibited-use firewall and controls where it conflicts for programmatic use.
6. Contact
Questions about these terms or about a permitted use: legal@fonteum.com. API and MCP access questions: hello@fonteum.com.