Two federal exclusion lists, and they don't match: the OIG LEIE–SAM.gov overlap

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.

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.

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.

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 re-check any Fonteum snapshot by re-hashing the published bytes against its signed attestation. Read every result as a screening aid: re-confirm any match against the primary source before acting, and read the absence of a match as "nothing in the lists Fonteum currently holds," never as a guarantee that none exists.

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.