{ "study": { "slug": "federal-exclusion-list-overlap-2026", "title": "Two federal exclusion lists, and they don't match: the OIG LEIE–SAM.gov overlap", "standfirst": "Only 47.9% of NPI-identified providers under an active federal exclusion — 3,747 of 7,827 — appear on both U.S. federal exclusion lists, the HHS-OIG LEIE and GSA SAM.gov. A SAM.gov-only screen misses 3,133 actively OIG-excluded providers, 45.5% of the LEIE. OIG LEIE release 2026-05-08; SAM.gov as of 2026-06-19.", "desk": "financial-distress", "article_type": "Original Research", "published": "2026-06-22", "issue": 88, "doi": "10.5072/fonteum/federal-exclusion-list-overlap-2026", "url": "https://fonteum.com/research/federal-exclusion-list-overlap-2026", "methodology_version": "federal-list-overlap/v1" }, "data_as_of": "2026-06-19", "datasets": [ { "slug": "oig-leie", "name": "OIG LEIE", "publisher": "HHS OIG — List of Excluded Individuals/Entities", "upstream_url": null } ], "key_findings": [ { "number": "47.9%", "finding": "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", "dataset": "oig-leie" }, { "number": "3,133", "finding": "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", "dataset": "sam-exclusions" }, { "number": "947", "finding": "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", "dataset": "sam-exclusions" }, { "number": "6,880", "finding": "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)", "dataset": "oig-leie" }, { "number": "10.3%", "finding": "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", "dataset": "oig-leie" } ], "faqs": [ { "q": "Aren't the OIG LEIE and SAM.gov the same exclusion list?", "a": "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." }, { "q": "If OIG exclusions are reciprocal, how can SAM.gov be missing 3,133 of them?", "a": "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." }, { "q": "What does this mean for an organization screening exclusions for billing or program-integrity compliance?", "a": "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." }, { "q": "Why is the comparison limited to providers with an NPI?", "a": "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." }, { "q": "Does this study name or rank any excluded provider?", "a": "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." }, { "q": "Can I reproduce these numbers?", "a": "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." } ], "citation": { "apa": "Fonteum Research. (2026, June 22). Two federal exclusion lists, and they don't match: the OIG LEIE–SAM.gov overlap. Fonteum Research, Issue 88. https://doi.org/10.5072/fonteum/federal-exclusion-list-overlap-2026", "url": "https://fonteum.com/research/federal-exclusion-list-overlap-2026" }, "reproducible_sql": "-- The federal exclusion-list overlap: OIG LEIE vs SAM.gov\n-- Methodology version: federal-list-overlap/v1\n--\n-- Question: of the providers under an *active* federal exclusion that can be\n-- identified by a National Provider Identifier (NPI), how many appear on BOTH\n-- federal lists — the HHS-OIG List of Excluded Individuals and Entities (LEIE)\n-- and the GSA SAM.gov exclusion/debarment registry — versus only one?\n--\n-- Sources (public, read-only, U.S. Government Works / 17 U.S.C. §105):\n-- oig_leie_exclusions — OIG LEIE monthly bulk download, release 2026-05-08\n-- (published current-active only; reinstated parties drop off)\n-- sam_exclusions — SAM.gov / GSA exclusion & debarment registry, as of 2026-06-19\n--\n-- Match key: the 10-digit NPI only, btrim-normalized. A name is NEVER used to\n-- assert a cross-list match. Listings, not deduplicated identities, are counted\n-- on each side before the distinct-NPI reduction; the comparison set is the\n-- distinct NPI on each list. Aggregate counts only — no party is named.\n\nWITH leie AS (\n -- LEIE is published current-active, so no in-force filter is needed.\n SELECT DISTINCT btrim(npi) AS npi\n FROM oig_leie_exclusions\n WHERE btrim(npi) ~ '^[0-9]{10}$'\n),\nsam AS (\n -- SAM accumulates terminated records, so restrict to in-force exclusions:\n -- termination_date is null or still in the future relative to today.\n SELECT DISTINCT btrim(npi) AS npi\n FROM sam_exclusions\n WHERE btrim(npi) ~ '^[0-9]{10}$'\n AND (termination_date IS NULL OR termination_date > current_date)\n),\nu AS (SELECT npi FROM leie UNION SELECT npi FROM sam)\nSELECT\n (SELECT count(*) FROM leie) AS leie_active_npi, -- 6,880\n (SELECT count(*) FROM sam) AS sam_active_npi, -- 4,694\n (SELECT count(*) FROM leie l WHERE EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS on_both, -- 3,747\n (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi)) AS leie_only,-- 3,133\n (SELECT count(*) FROM sam s WHERE NOT EXISTS (SELECT 1 FROM leie l WHERE l.npi=s.npi)) AS sam_only,-- 947\n (SELECT count(*) FROM u) AS union_npi, -- 7,827\n round(100.0 * (SELECT count(*) FROM leie l WHERE NOT EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi))\n / (SELECT count(*) FROM leie), 1) AS leie_only_pct_of_leie, -- 45.5\n round(100.0 * (SELECT count(*) FROM leie l WHERE EXISTS (SELECT 1 FROM sam s WHERE s.npi=l.npi))\n / (SELECT count(*) FROM u), 1) AS both_pct_of_union; -- 47.9\n\n-- Context: NPI coverage on the federal lists is itself sparse, so this overlap\n-- describes the identifier-matchable subset only.\n-- SELECT count(*) AS leie_total, -- 68,055\n-- count(*) FILTER (WHERE btrim(npi) ~ '^[0-9]{10}$') AS leie_with_npi, -- 7,025 (10.3%)\n-- FROM oig_leie_exclusions;", "license": "U.S. Government Works (federal sources; 17 U.S.C. §105)", "generated_by": "Fonteum — https://fonteum.com", "notes": "Aggregate, source-traced figures frozen to the snapshot above. Reproduce by running reproducible_sql against the cited federal dataset; no per-entity records are included." }