Aren't the OIG LEIE and SAM.gov the same exclusion list?

No. The OIG List of Excluded Individuals and Entities (LEIE) is the HHS Office of Inspector General's registry of parties barred from federal health programs. SAM.gov is the GSA-administered government-wide exclusion and debarment registry that absorbed the old EPLS. OIG exclusions are supposed to flow into SAM.gov reciprocally, but the two are maintained on different systems and timelines — and on NPI-identified providers they agree on only 47.9% (3,747 of a 7,827 union). They are two lists, not one.

If OIG exclusions are reciprocal, how can SAM.gov be missing 3,133 of them?

Reciprocal posting is the design, not a guarantee of completeness. SAM.gov's healthcare records are dominated by terminated entries that age out of the in-force set, while the LEIE publishes only currently-active exclusions. When you compare the two current-active sets by NPI, 3,133 of the 6,880 NPI-identified LEIE exclusions have no in-force SAM.gov record at all — and the same NPIs are absent whether or not the SAM termination-date filter is applied, so they are genuinely not in SAM, not merely terminated there.

What does this mean for an organization screening exclusions for billing or program-integrity compliance?

A single federal list is not a complete federal check. The OIG's own guidance is to screen every applicable list before billing federal programs for, or contracting with, a provider, vendor, or supplier — and on an ongoing basis. Across these two federal lists, a SAM.gov-only screen misses 3,133 actively OIG-excluded providers and an OIG-LEIE-only screen misses 947 on SAM.gov. Only the two lists together close each other's gaps, and that is before the state Medicaid lists are added.

Why is the comparison limited to providers with an NPI?

Because a National Provider Identifier is the only key that supports a defensible cross-list match. Only 10.3% of LEIE records (7,025 of 68,055) carry an NPI, and SAM.gov's in-force NPI coverage is sparser still, so this overlap describes the identifier-matchable subset only. Records with no NPI are reported separately and are never matched by name — a name is not a defensible identity assertion. The matchable figure is a floor on the divergence, not a ceiling.

Does this study name or rank any excluded provider?

No. Every figure is an aggregate count of how many NPIs fall on each list. No individual or business is named, surfaced, or attached to any provider profile, and no conduct is inferred. A presence or absence on a list is an administrative exclusion-list fact on the date queried, not a finding of wrongdoing.

Can I reproduce these numbers?

Yes. Every figure is a direct NPI join between the public oig_leie_exclusions and sam_exclusions tables, frozen to the OIG LEIE 2026-05-08 release and the SAM.gov 2026-06-19 ingest. The exact SQL is published in the reproducibility block and downloadable from this page; each count resolves to specific rows in specific frozen federal snapshots, and no match is inferred from a name.

OIG LEIE vs SAM.gov: the federal exclusion-list

Name: Two federal exclusion lists, and they don't match: the OIG LEIE–SAM.gov overlap — OIG LEIE
Creator: Fonteum LLC
Published: 2026-06-22
License: https://creativecommons.org/licenses/by/4.0/

Key findings

47.9%

of NPI-identified providers under an active federal exclusion (3,747 of 7,827) appear on both federal lists — the OIG LEIE and SAM.gov; the majority sit on only one
oig-leie · CMS

3,133

actively OIG-LEIE-excluded providers — 45.5% of the 6,880 NPI-identified — have no record at all on SAM.gov, so a SAM.gov-only screen clears them as having nothing on file
sam-exclusions · CMS

947

providers carry an in-force SAM.gov exclusion but no OIG LEIE record — the gap runs both ways, though the LEIE is the larger healthcare list
sam-exclusions · CMS

6,880

distinct NPI-identified active exclusions sit on the OIG LEIE versus 4,694 on SAM.gov's in-force registry — neither single list is the complete federal picture (union: 7,827)
oig-leie · CMS

10.3%

of all 68,055 OIG LEIE records carry an NPI at all (7,025), so this cross-list comparison covers only the identifier-matchable subset; no-NPI records are reported separately, never matched by name
oig-leie · CMS

The United States runs two federal exclusion lists, and most healthcare compliance programs are told to check both. The first is the OIG List of Excluded Individuals and Entities — the LEIE — the HHS Office of Inspector General's registry of parties barred from Medicare, Medicaid, and other federal health programs. The second is SAM.gov, the GSA-administered, government-wide exclusion and debarment registry that absorbed the old Excluded Parties List System. The common assumption is that SAM.gov is the consolidated one-stop check, with OIG exclusions flowing into it reciprocally.

This study tests that assumption against the data. It joins the two federal lists on the National Provider Identifier and asks a simple question: of the providers under an active federal exclusion that can be identified by NPI, how many appear on both lists — and how many on only one?

The two lists agree on fewer than half of providers

Across the identifier-matchable set, 3,747 of 7,827 NPI-identified providers under an active federal exclusion — 47.9% — appear on both the OIG LEIE and SAM.gov. The other 4,080 sit on exactly one of the two lists. The OIG LEIE holds 6,880 NPI-identified active exclusions; SAM.gov's in-force registry holds 4,694; their union is 7,827.

Federal exclusion list	Active NPI-identified exclusions	On both lists	On this list only
OIG LEIE	6,880	3,747	3,133
SAM.gov (in-force)	4,694	3,747	947
Union (either list)	7,827	3,747	—

The match is made on the 10-digit NPI only, normalized for whitespace; a name is never used to assert that two records are the same provider. The LEIE is published current-active, so no in-force filter is needed on that side; SAM.gov accumulates terminated entries, so it is restricted to records whose termination date is null or still in the future.

Two federal lists, one provider on only one of them. The "consolidated" federal exclusion picture is split across two registries that agree on fewer than half the providers either one holds.

What a single-list screen misses

The practical form of the gap is what each list leaves out. Screen SAM.gov alone — the registry many procurement-driven compliance programs treat as the federal check — and you miss 3,133 actively OIG-excluded providers, 45.5% of the 6,880 NPI-identified LEIE exclusions. Screen the OIG LEIE alone and you miss 947 providers carrying an in-force SAM.gov exclusion.

If you screen…	NPI-identified active exclusions you see	Active exclusions on the other federal list you miss
SAM.gov only	4,694	3,133
OIG LEIE only	6,880	947
Both federal lists	7,827	0 (of these two lists)

The asymmetry is expected: the LEIE is the dedicated healthcare exclusion list and is the larger NPI-identified set, so the bigger blind spot belongs to a SAM.gov-only screen. But the gap runs in both directions, and neither single list is the complete federal picture.

Why the two federal lists diverge

The divergence is structural, not a data error. Reciprocal posting of OIG exclusions into SAM.gov is the design, but it is neither instantaneous nor complete. The two registries run on different systems, ingest on different cadences, and treat record lifecycle differently: the LEIE drops a party the moment it is reinstated, while SAM.gov retains terminated records with an end date. When the two current-active sets are compared by identifier, a large standing set of OIG exclusions has no live SAM.gov counterpart — and the same NPIs are absent from SAM.gov whether or not its termination-date filter is applied, so they are genuinely not in SAM.gov rather than merely terminated there.

This compounds a pattern we documented from the state side. In the state exclusion blind spot, adding SAM.gov on top of the LEIE recovered only a handful of state-barred providers, because both federal lists lag state action. Here the same lists are compared directly to each other, and they disagree on their own terms: a provider can be actively excluded on one federal registry and absent from the other. The companion reference cut, who actually gets barred from Medicare and why, shows why the LEIE is the deeper healthcare list — most of it is downstream of state licensing discipline that never reaches SAM.gov at all.

The identifier-matchable subset is itself small

Every figure above describes NPI-identified providers, and that is a deliberately narrow window. Only 10.3% of the 68,055 OIG LEIE records carry an NPI (7,025 records, 6,880 distinct identifiers); SAM.gov's in-force NPI coverage is sparser still. The lists are not physician registries — they cover suppliers, billing agents, aides, owners, and entities that mostly never held an NPI.

Records with no NPI cannot be matched across lists by identifier, and we do not guess by name — a same-name coincidence is not a defensible identity assertion. They are excluded from the matchable set and reported as a separate limitation. The practical effect is that the 47.9% overlap is a floor on the divergence: the unmatchable majority can only widen it, never close it.

So the honest read is two-layered. Among the minority of federal exclusions that an automated, identifier-based screen can even see, fewer than half are on both lists. The larger no-NPI population is unreachable by identifier on either list, and a complete check has to fall back to name-and-date matching against each primary source.

What this means for screening compliance

The magnitude puts a number on a familiar warning: checking one federal exclusion list is not the same as checking the federal lists. Across the NPI-identified set, the OIG LEIE and SAM.gov agree on only 47.9% of providers, a SAM.gov-only screen misses 3,133 active OIG exclusions, and a LEIE-only screen misses 947 on SAM.gov. Billing a federal program for an item or service furnished by an excluded party carries civil-monetary-penalty exposure under a "knew or should have known" standard, so the gap is a compliance cost, not a curiosity.

Fonteum exposes both federal lists — plus the state Medicaid layer — through a single NPI lookup, so a "barred anywhere on the lists we hold" answer does not depend on which single registry a screener happened to check. Start a free exclusion and sanction-list screen, inspect the underlying OIG LEIE dataset, and, when a concrete snapshot id includes attestation metadata, re-check that snapshot by comparing its published bytes with the stored digest. That snapshot check does not sign each result. Read every result as a screening aid: re-confirm any match against the primary source before acting. An absence becomes a no-match only when serving coverage reconciles to the latest comparable attested artifact; otherwise it is indeterminate and is not a clearance.

Methodology

Every figure is a direct join between two public, read-only Postgres tables: oig_leie_exclusions (the OIG monthly LEIE bulk download, release 2026-05-08, 68,055 active records, 7,025 with an NPI) and sam_exclusions (the SAM.gov / GSA government-wide exclusion and debarment registry, 324,126 records, as of the 2026-06-19 ingest). The match key is the 10-digit NPI, trimmed of whitespace; a name is never used to assert a match.

The LEIE is published current-active — the OIG removes reinstated parties — so it needs no in-force filter. SAM.gov retains terminated records, so it is restricted to in-force exclusions: termination date null or still in the future relative to the publish date, the same test our production exclusion lookup applies. The comparison sets are the distinct NPIs on each side; on_both is the intersection, leie_only and sam_only the two differences, and the percentages are taken against the LEIE set and against the union. The exact SQL is in the reproducibility block below and downloadable from this page, and the provenance methodology documents the source-provenance contract. Methodology version: federal-list-overlap/v1.

Limitations

NPI is the floor, not the ceiling. Only 10.3% of LEIE records carry an NPI, and SAM.gov's in-force NPI coverage is sparser; the overlap describes the identifier-matchable subset only. No-NPI records are reported separately, never matched by name, and can only widen the divergence.
Two federal lists, not the whole picture. This study compares the OIG LEIE and SAM.gov to each other. It does not add the state Medicaid exclusion lists, which we measured separately in the exclusion gap; the complete-screen shortfall is larger once states are included.
Different lists, different bases. An OIG exclusion and a SAM.gov debarment rest on different legal authorities and program scopes. This study measures only whether the same NPI appears on each list; it never treats one as a substitute for the other or infers conduct from either.
Snapshot, not real time. Both lists are point-in-time — the LEIE the 2026-05-08 release, SAM.gov the 2026-06-19 ingest. A record in transit between releases can look absent from a list it will soon appear on.
A compliance signal, aggregate-only. Exclusion counts are an enforcement and screening signal, never a measure of care quality, and never a wrongdoing finding about any provider. No individual excluded party is named, surfaced, or attached to any provider profile in this study.

Sources

OIG LEIE — online database and monthly downloads — the federal healthcare exclusion list and the first comparison anchor.
SAM.gov — exclusions and debarment registry — the GSA-administered government-wide exclusion list and the second comparison anchor.
OIG — effect of an exclusion (screening duty, civil monetary penalties) — the obligation to screen all applicable lists and the "knew or should have known" penalty standard.
Fonteum — OIG LEIE dataset — the federal exclusion data behind this study, source-stamped and downloadable.
42 U.S.C. § 1320a-7 (Social Security Act § 1128) — the federal exclusion statute, including the permissive §1128(b) authorities under which state actions are adopted.

Frequently asked questions

Aren't the OIG LEIE and SAM.gov the same exclusion list?: No. The OIG List of Excluded Individuals and Entities (LEIE) is the HHS Office of Inspector General's registry of parties barred from federal health programs. SAM.gov is the GSA-administered government-wide exclusion and debarment registry that absorbed the old EPLS. OIG exclusions are supposed to flow into SAM.gov reciprocally, but the two are maintained on different systems and timelines — and on NPI-identified providers they agree on only 47.9% (3,747 of a 7,827 union). They are two lists, not one.
If OIG exclusions are reciprocal, how can SAM.gov be missing 3,133 of them?: Reciprocal posting is the design, not a guarantee of completeness. SAM.gov's healthcare records are dominated by terminated entries that age out of the in-force set, while the LEIE publishes only currently-active exclusions. When you compare the two current-active sets by NPI, 3,133 of the 6,880 NPI-identified LEIE exclusions have no in-force SAM.gov record at all — and the same NPIs are absent whether or not the SAM termination-date filter is applied, so they are genuinely not in SAM, not merely terminated there.
What does this mean for an organization screening exclusions for billing or program-integrity compliance?: A single federal list is not a complete federal check. The OIG's own guidance is to screen every applicable list before billing federal programs for, or contracting with, a provider, vendor, or supplier — and on an ongoing basis. Across these two federal lists, a SAM.gov-only screen misses 3,133 actively OIG-excluded providers and an OIG-LEIE-only screen misses 947 on SAM.gov. Only the two lists together close each other's gaps, and that is before the state Medicaid lists are added.
Why is the comparison limited to providers with an NPI?: Because a National Provider Identifier is the only key that supports a defensible cross-list match. Only 10.3% of LEIE records (7,025 of 68,055) carry an NPI, and SAM.gov's in-force NPI coverage is sparser still, so this overlap describes the identifier-matchable subset only. Records with no NPI are reported separately and are never matched by name — a name is not a defensible identity assertion. The matchable figure is a floor on the divergence, not a ceiling.
Does this study name or rank any excluded provider?: No. Every figure is an aggregate count of how many NPIs fall on each list. No individual or business is named, surfaced, or attached to any provider profile, and no conduct is inferred. A presence or absence on a list is an administrative exclusion-list fact on the date queried, not a finding of wrongdoing.
Can I reproduce these numbers?: Yes. Every figure is a direct NPI join between the public oig_leie_exclusions and sam_exclusions tables, frozen to the OIG LEIE 2026-05-08 release and the SAM.gov 2026-06-19 ingest. The exact SQL is published in the reproducibility block and downloadable from this page; each count resolves to specific rows in specific frozen federal snapshots, and no match is inferred from a name.

Who uses this data

The source data behind this study is public

Compliance teams, journalists, and researchers work from the same federal source families cited above — queried by NPI or facility identifier through Fonteum’s open dataset pages and API. Every figure traces to a frozen, downloadable snapshot you can reproduce yourself.

Browse OIG LEIE→Query the API →How we built this →

Datasets used

OIG LEIE

Reproducibility

Every claim, reproducible

The SQL

federal-exclusion-list-overlap-2026.sql

-- The federal exclusion-list overlap: OIG LEIE vs SAM.gov
-- Methodology version: federal-list-overlap/v1
--
-- Question: of the providers under an *active* federal exclusion that can be
-- identified by a National Provider Identifier (NPI), how many appear on BOTH
-- federal lists — the HHS-OIG List of Excluded Individuals and Entities (LEIE)
-- and the GSA SAM.gov exclusion/debarment registry — versus only one?
--
-- Sources (public, read-only, U.S. Government Works / 17 U.S.C. §105):
--   oig_leie_exclusions — OIG LEIE monthly bulk download, release 2026-05-08
--                         (published current-active only; reinstated parties drop off)
--   sam_exclusions      — SAM.gov / GSA exclusion & debarment registry, as of 2026-06-19
--
-- Match key: the 10-digit NPI only, btrim-normalized. A name is NEVER used to
-- assert a cross-list match. Listings, not deduplicated identities, are counted
-- on each side before the distinct-NPI reduction; the comparison set is the
-- distinct NPI on each list. Aggregate counts only — no party is named.

WITH leie AS (
  -- LEIE is published current-active, so no in-force filter is needed.
  SELECT DISTINCT btrim(npi) AS npi
  FROM   oig_leie_exclusions
  WHERE  btrim(npi) ~ '^[0-9]{10}$'
),
sam AS (
  -- SAM accumulates terminated records, so restrict to in-force exclusions:
  -- termination_date is null or still in the future relative to today.
  SELECT DISTINCT btrim(npi) AS npi
  FROM   sam_exclusions
  WHERE  btrim(npi) ~ '^[0-9]{10}$'
    AND  (termination_date IS NULL OR termination_date > current_date)
),
u AS (SELECT npi FROM leie UNION SELECT npi FROM sam)
SELECT
  (SELECT count(*) FROM leie)                                              AS leie_active_npi,        -- 6,880
  (SELECT count(*) FROM sam)                                               AS sam_active_npi,         -- 4,694
  (SELECT count(*) FROM leie l WHERE     EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS on_both,  -- 3,747
  (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS leie_only,-- 3,133
  (SELECT count(*) FROM sam s  WHERE NOT EXISTS (SELECT 1 FROM leie l WHERE l.npi=s.npi)) AS sam_only,-- 947
  (SELECT count(*) FROM u)                                                 AS union_npi,              -- 7,827
  round(100.0 * (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi))
              / (SELECT count(*) FROM leie), 1)                            AS leie_only_pct_of_leie,  -- 45.5
  round(100.0 * (SELECT count(*) FROM leie l WHERE     EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi))
              / (SELECT count(*) FROM u), 1)                               AS both_pct_of_union;      -- 47.9

-- Context: NPI coverage on the federal lists is itself sparse, so this overlap
-- describes the identifier-matchable subset only.
--   SELECT count(*)                                          AS leie_total,        -- 68,055
--          count(*) FILTER (WHERE btrim(npi) ~ '^[0-9]{10}$') AS leie_with_npi,     -- 7,025 (10.3%)
--   FROM oig_leie_exclusions;

The snapshot

dataset_id	oig-leie
snapshot_date	2026-06-19

The JOINs

match key: oig_leie_exclusions.npi = sam_exclusions.npi  -- 10-digit NPI, btrim, never a name match
leie set = distinct btrim(npi) ~ '^[0-9]{10}$' from oig_leie_exclusions  -- LEIE is published current-active only
sam set = distinct in-force NPI from sam_exclusions  -- in_force = termination_date IS NULL OR termination_date > current_date
on_both = NPI present in both sets  -- 3,747
leie_only = LEIE NPI absent from the SAM set  -- 3,133 / 6,880 = 45.5%
sam_only = SAM NPI absent from the LEIE set  -- 947
union = 7,827 distinct NPIs; both / union = 47.9%

The pipeline version

methodology_version

federal-list-overlap/v1

Reproduce this

Run the exact query against the frozen 2026-06-19.

-- The federal exclusion-list overlap: OIG LEIE vs SAM.gov -- Methodology version: federal-list-overlap/v1 -- -- Question: of the providers under an *active* federal exclusion that can be -- identified by a National Provider Identifier (NPI), how many appear on BOTH -- federal lists — the HHS-OIG List of Excluded Individuals and Entities (LEIE) -- and the GSA SAM.gov exclusion/debarment registry — versus only one? -- -- Sources (public, read-only, U.S. Government Works / 17 U.S.C. §105): -- oig_leie_exclusions — OIG LEIE monthly bulk download, release 2026-05-08 -- (published current-active only; reinstated parties drop off) -- sam_exclusions — SAM.gov / GSA exclusion & debarment registry, as of 2026-06-19 -- -- Match key: the 10-digit NPI only, btrim-normalized. A name is NEVER used to -- assert a cross-list match. Listings, not deduplicated identities, are counted -- on each side before the distinct-NPI reduction; the comparison set is the -- distinct NPI on each list. Aggregate counts only — no party is named. WITH leie AS ( -- LEIE is published current-active, so no in-force filter is needed. SELECT DISTINCT btrim(npi) AS npi FROM oig_leie_exclusions WHERE btrim(npi) ~ '^[0-9]{10}$' ), sam AS ( -- SAM accumulates terminated records, so restrict to in-force exclusions: -- termination_date is null or still in the future relative to today. SELECT DISTINCT btrim(npi) AS npi FROM sam_exclusions WHERE btrim(npi) ~ '^[0-9]{10}$' AND (termination_date IS NULL OR termination_date > current_date) ), u AS (SELECT npi FROM leie UNION SELECT npi FROM sam) SELECT (SELECT count(*) FROM leie) AS leie_active_npi, -- 6,880 (SELECT count(*) FROM sam) AS sam_active_npi, -- 4,694 (SELECT count(*) FROM leie l WHERE EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS on_both, -- 3,747 (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS leie_only,-- 3,133 (SELECT count(*) FROM sam s WHERE NOT EXISTS (SELECT 1 FROM leie l WHERE l.npi=s.npi)) AS sam_only,-- 947 (SELECT count(*) FROM u) AS union_npi, -- 7,827 round(100.0 * (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) / (SELECT count(*) FROM leie), 1) AS leie_only_pct_of_leie, -- 45.5 round(100.0 * (SELECT count(*) FROM leie l WHERE EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) / (SELECT count(*) FROM u), 1) AS both_pct_of_union; -- 47.9 -- Context: NPI coverage on the federal lists is itself sparse, so this overlap -- describes the identifier-matchable subset only. -- SELECT count(*) AS leie_total, -- 68,055 -- count(*) FILTER (WHERE btrim(npi) ~ '^[0-9]{10}$') AS leie_with_npi, -- 7,025 (10.3%) -- FROM oig_leie_exclusions;

Download the data: SQL · JSON · CSV

Cite this study

Citation-ready for researchers and AI.

Fonteum Research Bureau (2026). Two federal exclusion lists, and they don't match: the OIG LEIE–SAM.gov overlap. OIG LEIE, snapshot 2026-06-19. https://fonteum.com/research/federal-exclusion-list-overlap-2026

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The cited snapshot identifies the federal file. Where an attestation is present, its file hash can be re-derived; figures are not individually signed.

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Federal source citations

OIG LEIE · snapshot 2026-06-19 · federal source family · US-Government-Works

Fonteum LLC · June 22, 2026 · All figures trace to the frozen federal-data snapshot cited above.