state-exclusions · CMS
sam-exclusions · CMS
state-exclusions · CMS
state-exclusions · CMS
The OIG List of Excluded Individuals and Entities — the LEIE — is the list most compliance tools treat as the master federal registry of providers barred from Medicare, Medicaid, and other federal health programs. The SAM.gov debarment registry is the second federal list a thorough screen adds. But neither is the only list that bars a provider. Every state Medicaid agency runs its own exclusion program, on its own authority and its own clock. When a provider sits on a state list but not the federal ones, the disagreement is the story: that provider is invisible to anyone who screens federally and stops there.
This study measures the size of that blind spot from the state side. It joins the state Medicaid exclusion records Fonteum holds — 13 states — against both federal lists on the National Provider Identifier, and asks two questions a single-list comparison cannot: how many state-barred providers does the full federal screening stack still miss, and how many providers are barred across several states at once. It is the cross-state and second-federal-list extension of our earlier LEIE-only cut, the exclusion gap; where the excluded-provider landscape counted the union of every list, this one takes the state lists as the starting point and tracks what the federal stack does and does not recover.
The blind spot, in one number
64.4% of NPI-identified state-excluded providers carry no in-force OIG LEIE record: 3,188 of 4,949 across the 13 ingested states. Put the other way, a federal-LEIE-only screen catches only 1,761 of the 4,949 state-barred providers — it returns the rest as having no exclusion on file.
That is the headline an employer or payer feels directly. The OIG's own guidance is that a screen must run against every applicable list before a provider is hired, contracted, or billed through — federal and the relevant state Medicaid lists — and on an ongoing basis. Employing or contracting an excluded party in a federally billable role carries civil-monetary-penalty exposure under a "knew or should have known" standard. A federal-only screen does not meet that bar, and the 3,188 is how many providers fall through it across these 13 states alone.
A second federal list barely helps
The obvious reply is to add a second federal source. It does far less than expected. Layering the SAM.gov / GSA exclusion and debarment registry on top of the OIG LEIE recovers only 191 of the 3,188. After both federal lists are checked, 2,997 NPI-identified state-excluded providers — 60.6% of the 4,949 — are on neither.
| Screen applied | State-excluded providers still cleared | Share of 4,949 |
|---|---|---|
| OIG LEIE only | 3,188 | 64.4% |
| OIG LEIE and SAM.gov debarment | 2,997 | 60.6% |
| Recovered by adding SAM.gov | 191 | 3.8 pts |
A second federal list barely moves the number. Of the state-barred providers the OIG LEIE misses, all but 191 are missing from the SAM.gov debarment registry too.
The reason the second list adds so little is the same reason the first one misses: both federal registries are downstream of state action, and both lag it. A state Medicaid termination can be entered well before — or entirely without — a parallel federal exclusion or a SAM.gov debarment. Stacking two lagging federal lists does not recover a bar that has not propagated to either of them. The state list is where many of these decisions land first.
Why the state bars don't reach the federal lists
The gap is structural, not a data error. State Medicaid agencies exclude providers under state authority for Medicaid-specific reasons, and a federal action does not automatically follow. The OIG may adopt a state action under its permissive §1128(b) authority — most commonly §1128(b)(4) for a state license revocation, surrender, or suspension — but that adoption is discretionary and lagged, and many state bars never cross over at all. We documented the federal side of this in who actually gets barred from Medicare and why: the single largest basis on the LEIE is itself a downstream echo of state licensing discipline.
Timing compounds it. An exclusion is a trailing record on every list, and the trailing records do not move together. A provider can be off a state Medicaid program long before a federal list catches up — the same cadence mismatch we measured between a triggering event and CMS deactivation in the deactivation-lag study. The federal–state direction we measured directly in the exclusion gap; this study adds the second federal list and the cross-state view to it.
The cross-state dimension
The state lists also disagree with each other in a way no federal comparison can show: some providers are barred in more than one state at the same time. 198 of the 4,949 NPIs appear on two or more of the 13 state lists. The distribution is concentrated near the low end, but it has a long tail — one provider sits on seven different states' exclusion lists.
| State lists a single NPI appears on | Providers |
|---|---|
| 1 state | 4,751 |
| 2 states | 186 |
| 3 states | 11 |
| 7 states | 1 |
| 2 or more states | 198 |
A provider barred across several state Medicaid programs is, on its face, the least ambiguous kind of standing exclusion — yet 82 of these 198 multi-state providers still carry no OIG LEIE record. A federal-only screen clears a provider barred in two, three, or seven states as having nothing on file. The cross-state overlap is small in count but sharp in implication: it is the subset where the federal blind spot is hardest to explain as a one-cycle timing lag.
How the blind spot breaks down by state
No single state drives the headline. New York carries the largest matchable population and Tennessee the smallest, and the federal-invisible share holds across the range.
| State | NPI-identified state-excluded | Not on OIG LEIE |
|---|---|---|
| New York (OMIG) | 2,259 | 1,352 |
| Pennsylvania (DHS) | 973 | 568 |
| Ohio (ODM) | 673 | 363 |
| Iowa (Medicaid) | 313 | 263 |
| Maryland (MDH) | 264 | 222 |
| Washington (HCA) | 210 | 178 |
| North Carolina (DHHS) | 149 | 128 |
| Mississippi (DOM) | 138 | 106 |
| New Hampshire (DHHS) | 51 | 37 |
| North Dakota (HHS) | 47 | 28 |
| Montana (DPHHS) | 42 | 16 |
| Georgia (DCH-OIG) | 35 | 8 |
| Tennessee (TennCare) | 9 | 8 |
| All 13 states | 4,949 | 3,188 |
The records with no NPI at all
The matchable population is itself a minority of the data. 74.2% of state exclusion rows — 16,995 of 22,917 — carry no NPI at all. They name an excluded party with no identifier that maps to any federal list, so identifier-based screening cannot reach them in either direction.
| State exclusion rows | Count |
|---|---|
| Total rows (13 states) | 22,917 |
| With an NPI (matchable) | 5,922 |
| With no NPI (unmatchable by identifier) | 16,995 |
These rows are excluded from every matchable denominator above, because matching them would require a name match — and a name match is not a defensible identity assertion. We do not guess. But the practical implication is blunt: identifier-based screening, federal or state, cannot see three in four state exclusion records, 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: a federal screen — even a two-list federal screen — is not a complete exclusion check. Across these 13 states, 64.4% of NPI-identified state-barred providers are outside the OIG LEIE, and 60.6% are outside both federal lists. Adding the SAM.gov debarment registry, the standard second federal source, closes only about 6% of the LEIE-only gap.
Two operational lessons follow. First, federal breadth does not substitute for state currency: the federal lists are national but lagging, while the state lists are program-specific but current, and only the union of the layers — read across frozen point-in-time snapshots — closes the gaps in each. Second, identifier-only screening is a floor, not a ceiling, because three in four state records carry no NPI. Fonteum exposes the layers through a single NPI lookup — the state exclusion data and the federal OIG LEIE — so a "barred anywhere on the lists we hold" answer does not depend on which single list a screener happened to check. It is 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 across three public, read-only Postgres tables as observed July 14, 2026: state_exclusions (the State Exclusion Ring — 13 state Medicaid programs, 22,917 raw rows), oig_leie_exclusions (the OIG monthly LEIE bulk download, release 2026-05-08, 68,055 rows, 7,025 with an NPI), and sam_exclusions (the SAM.gov / GSA federal exclusion and debarment registry, 323,930 active and unterminated rows, 37,443 with an NPI, representing 4,694 distinct matchable NPIs). The join key is the 10-digit NPI, trimmed of whitespace; a name is never used to assert a match.
A record is treated as in force when its reinstatement date (state, LEIE) or termination date (SAM) is null or still in the future relative to the publish date — the same test the production exclusion lookup applies, and applied identically to every table. The matchable denominator is the set of distinct, in-force, NPI-identified state-excluded providers; records with no NPI are excluded from it and reported separately. The federally-invisible count is the subset of those NPIs with no in-force row in oig_leie_exclusions; the both-lists-invisible count is the subset absent from oig_leie_exclusions and sam_exclusions. Cross-state overlap counts distinct NPIs appearing on two or more distinct state lists. The exact SQL is in the reproducibility block below, and the provenance methodology documents the source-provenance contract. Methodology version: state-blind-spot/v1.
Limitations
- Thirteen states, not fifty. Coverage is New York, Pennsylvania, Ohio, Iowa, Maryland, Washington, North Carolina, Mississippi, New Hampshire, North Dakota, Montana, Georgia, and Tennessee. Every figure describes the 13 state Medicaid programs Fonteum currently ingests, not the nation. The blind spot in the 37 states not yet ingested is unmeasured here.
- NPI is the floor, not the ceiling. 74.2% of state exclusion rows carry no NPI and cannot be matched to any federal list by identifier; they are reported separately, never guessed at by name. The headline figures describe the matchable, NPI-identified set only.
- A state exclusion is not a federal one. State Medicaid and federal exclusions rest on different legal bases, authorities, and program scopes. This study measures only whether the same NPI appears on each list; it never treats a state bar as a federal one or infers conduct from either.
- Snapshot, not real time. All three lists are point-in-time. The results are production observations made July 14, 2026; the LEIE source release is 2026-05-08, while the 13 state sources and SAM.gov rows have source-specific cadences. A bar in transit between releases can leave a provider looking absent from a list it will soon appear on.
- Small-sample states are illustrative. Georgia, Montana, North Dakota, and Tennessee carry small matchable denominators, so their per-state shares are unstable and should be read as illustrative, not as stable estimates.
- 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 exclusion list and the first comparison anchor.
- SAM.gov — exclusions and debarment registry — the GSA-administered federal 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.
- New York OMIG — Medicaid exclusions — the largest state source in the ring.
- Pennsylvania DHS — sanctioned and precluded providers — the second-largest state source.
- Fonteum — state Medicaid exclusion data, all ingested states — the consolidated state exclusion layer across all 13 states.
- 42 U.S.C. § 1320a-7 (Social Security Act § 1128) — the federal exclusion statute, including the permissive §1128(b)(4) license-action authority.
Frequently asked questions
- How many state-excluded providers does a federal check miss?
- Across the 13 state Medicaid programs Fonteum currently ingests, 3,188 of 4,949 NPI-identified state-excluded providers — 64.4% — carry no in-force record on the federal OIG List of Excluded Individuals and Entities (LEIE). An organization that screens the federal LEIE alone returns nearly two in three state-barred providers as having no exclusion on file. The match is made on the National Provider Identifier only, never on a name.
- Does adding the SAM.gov debarment list close the gap?
- Barely. Layering the second federal list — the SAM.gov / GSA exclusion and debarment registry — on top of the OIG LEIE recovers only 191 of the 3,188. After both federal lists are checked, 2,997 NPI-identified state-excluded providers (60.6% of the 4,949) are still on neither. A second federal source closes roughly 6% of the federal-only blind spot, because both federal lists are downstream of, and lag, the state actions.
- Why would a provider be excluded by a state but absent from the federal lists?
- State Medicaid agencies run their own exclusion programs on their own authority and timeline. A state can bar a provider for a Medicaid-specific reason — a state license action, a state fraud referral, an administrative termination — without a federal OIG exclusion or SAM.gov debarment ever following. The federal lists can adopt many state actions under permissive authority, but adoption is discretionary and lagged, so a large standing set of state bars never reaches the federal files at all.
- How many providers are excluded in more than one state at once?
- 198 NPIs appear on two or more of the 13 state lists. The distribution is concentrated near the low end — 186 on two states, 11 on three — but one NPI sits on seven different states' exclusion lists. And 82 of the 198 multi-state providers carry no OIG LEIE record, so a federal-only screen clears a provider barred in multiple states as clean.
- Which states are included, and why not all 50?
- Thirteen state Medicaid programs publish a usable exclusion file and are ingested: New York (OMIG), Pennsylvania (DHS), Ohio (ODM), Iowa (Medicaid), Maryland (MDH), Washington (HCA), North Carolina (DHHS), Mississippi (DOM), New Hampshire (DHHS), North Dakota (HHS), Montana (DPHHS), Georgia (DCH-OIG), and Tennessee (TennCare). State Medicaid exclusion data is fragmented and inconsistently published, so coverage expands one primary source at a time. Every figure here describes the 13 ingested states, not the nation.
- What about state exclusions with no NPI?
- 74.2% of state exclusion rows — 16,995 of 22,917 — carry no NPI at all. They cannot be matched to any federal list by identifier, so identifier-based screening cannot reach them. They are excluded from the matchable denominator and reported separately rather than guessed at by name. The headline figures describe the matchable, NPI-identified set.
- Is a state exclusion the same as a federal one?
- No. A state Medicaid exclusion and a federal OIG exclusion rest on different legal bases, are issued by different authorities, and bar different programs. Neither implies the other, and this study never treats one as a substitute for the other — it measures only whether the same NPI appears on each list. No conduct or wrongdoing is inferred; these are administrative exclusion-list facts, reported in aggregate.
- Can I reproduce these numbers?
- Yes. Every figure is a direct NPI join across the public state_exclusions, oig_leie_exclusions, and sam_exclusions tables. The exact SQL is published in the reproducibility block below; each count resolves to specific rows in specific frozen snapshots, and no match is ever 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.
Datasets used
Reproducibility
Every claim, reproducible
The SQL
-- Excluded by a state, invisible to a federal check — fully reproducible query.
--
-- Question: of the providers (by NPI) carrying an ACTIVE state Medicaid
-- exclusion across the 13 state programs Fonteum currently ingests, how many
-- are NOT present on the federal OIG LEIE — i.e. how many a federal-only
-- screen would miss? And, layering the second federal list, how many are on
-- neither the OIG LEIE nor the SAM.gov / GSA debarment registry? Plus the
-- cross-state overlap: how many excluded NPIs appear on 2+ state lists.
--
-- This study extends the prior LEIE-only cut (federal-state-exclusion-gap-2026,
-- 10 states) two ways: (1) it tests the FULL federal screening stack — OIG LEIE
-- AND SAM.gov debarment — not a single list; (2) it adds the cross-state
-- dimension. Coverage is now 13 states (NY OH GA PA NC MD WA IA MS MT NH ND TN).
--
-- Sources (all public, read-only):
-- public.state_exclusions — State Exclusion Ring, 13 state Medicaid
-- programs, 22,917 rows (5,922 carry an NPI;
-- 16,995 — 74.2% — carry none). Data as of
-- observed 2026-07-14.
-- public.oig_leie_exclusions — OIG List of Excluded Individuals and
-- Entities, federal monthly bulk download,
-- release 2026-05-08, 68,055 active records
-- (7,025 carry an NPI).
-- public.sam_exclusions — SAM.gov / GSA federal exclusion & debarment
-- registry, 323,930 active and unterminated
-- rows (37,443 carry an NPI; 4,694 distinct
-- NPIs) as observed 2026-07-14.
--
-- Join key: NPI only (10-digit, btrim). We NEVER match on name — a name match
-- is not a defensible identity assertion, so rows with no NPI are excluded from
-- the matchable denominator and reported separately (see the no-NPI query).
--
-- "In force" mirrors the production exclusion lookup (src/lib/exclusions):
-- state / LEIE : reinstatement_date IS NULL OR reinstatement_date > today
-- SAM : termination_date IS NULL OR termination_date > today
-- (isCurrentlyExcluded in src/lib/exclusions/types.ts). The OIG/state files drop
-- reinstated parties, so the in-force set is "any row by NPI" net of future-dated
-- reinstatements. Audit date basis: DATE '2026-07-14'.
--
-- Every headline figure in the study resolves to one of the rows below.
-- ── HEADLINE: state-excluded NPIs invisible to a federal check ──────────────
-- audit-claim: federal-blind-spot
WITH state_inforce AS ( -- distinct in-force, NPI-identified state Medicaid exclusions
SELECT DISTINCT nullif(btrim(npi), '') AS npi
FROM public.state_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
),
leie_inforce AS ( -- distinct in-force, NPI-identified federal OIG exclusions
SELECT DISTINCT nullif(btrim(npi), '') AS npi
FROM public.oig_leie_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
),
sam_inforce AS ( -- distinct in-force, NPI-identified SAM.gov / GSA debarments
SELECT DISTINCT nullif(btrim(npi), '') AS npi
FROM public.sam_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND status = 'Active'
AND (termination_date IS NULL OR termination_date > DATE '2026-07-14')
), counts AS (
SELECT
(SELECT count(*) FROM state_inforce) AS state_inforce_npi,
(SELECT count(*) FROM state_inforce s
LEFT JOIN leie_inforce l USING (npi) WHERE l.npi IS NULL) AS not_on_leie,
(SELECT count(*) FROM state_inforce s
JOIN leie_inforce l USING (npi)) AS also_on_leie,
(SELECT count(*) FROM state_inforce s
LEFT JOIN leie_inforce l USING (npi)
LEFT JOIN sam_inforce sa USING (npi)
WHERE l.npi IS NULL AND sa.npi IS NULL) AS not_on_leie_nor_sam,
(SELECT count(*) FROM leie_inforce) AS leie_inforce_npi,
(SELECT count(*) FROM sam_inforce) AS sam_inforce_npi
)
SELECT
counts.*,
round(100.0 * not_on_leie / state_inforce_npi, 1) AS not_on_leie_pct,
not_on_leie - not_on_leie_nor_sam AS recovered_by_sam,
round(100.0 * not_on_leie_nor_sam / state_inforce_npi, 1) AS not_on_both_pct,
round(100.0 * not_on_leie / state_inforce_npi, 1)
- round(100.0 * not_on_leie_nor_sam / state_inforce_npi, 1) AS recovered_percentage_points,
round(
100.0 * (not_on_leie - not_on_leie_nor_sam) / not_on_leie,
1
) AS blind_spot_closed_pct
FROM counts;
-- state_inforce_npi not_on_leie also_on_leie not_on_leie_nor_sam leie_inforce_npi sam_inforce_npi
-- 4,949 3,188 1,761 2,997 6,880 4,694
-- => 3,188 / 4,949 = 64.4% of state-excluded NPIs carry NO in-force OIG LEIE record (federal-LEIE-only blind spot).
-- => Adding the SAM.gov debarment list recovers only 3,188 - 2,997 = 191 of them; 2,997 (60.6%) remain
-- invisible to BOTH federal lists. Difference 3.8 percentage points; 6.0% of the gap closed.
-- ── Cross-state overlap: NPIs barred across 2+ of the 13 state lists ─────────
-- audit-claim: cross-state-summary
WITH npi_states AS (
SELECT nullif(btrim(npi), '') AS npi, count(DISTINCT state) AS n_states
FROM public.state_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
GROUP BY 1
)
SELECT
count(*) AS distinct_npi, -- 4,949
count(*) FILTER (WHERE n_states >= 2) AS on_2plus_states, -- 198
count(*) FILTER (WHERE n_states = 1) AS on_1_state, -- 4,751
max(n_states) AS max_states -- 7
FROM npi_states;
-- Distribution of states-per-NPI (how many state lists a single NPI sits on):
-- audit-claim: cross-state-distribution
WITH npi_states AS (
SELECT nullif(btrim(npi), '') AS npi, count(DISTINCT state) AS n_states
FROM public.state_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
GROUP BY 1
)
SELECT n_states, count(*) AS npis FROM npi_states GROUP BY n_states ORDER BY n_states;
-- 1 state: 4,751 · 2 states: 186 · 3 states: 11 · 7 states: 1 (198 NPIs on 2+ states)
-- Of the multi-state (2+) NPIs, how many are STILL invisible to the federal LEIE:
-- audit-claim: multi-state-federal-gap
WITH npi_states AS (
SELECT nullif(btrim(npi), '') AS npi, count(DISTINCT state) AS n_states
FROM public.state_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
GROUP BY 1
),
leie_inforce AS (
SELECT DISTINCT nullif(btrim(npi), '') AS npi
FROM public.oig_leie_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
),
multi AS (SELECT npi FROM npi_states WHERE n_states >= 2)
SELECT
(SELECT count(*) FROM multi) AS multi_state_npi, -- 198
(SELECT count(*) FROM multi m LEFT JOIN leie_inforce l USING (npi)
WHERE l.npi IS NULL) AS multi_state_not_on_leie; -- 82
-- 82 of the 198 providers barred in 2+ states carry no OIG LEIE record — barred coast-to-coast,
-- yet a federal-only screen returns them clean.
-- ── Per-state contribution (in-force distinct NPI, and how many not on LEIE) ─
-- audit-claim: state-vector
WITH state_inforce AS (
SELECT DISTINCT state, nullif(btrim(npi), '') AS npi
FROM public.state_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
),
leie_inforce AS (
SELECT DISTINCT nullif(btrim(npi), '') AS npi
FROM public.oig_leie_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL
AND (reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14')
),
flagged AS (
SELECT s.state, s.npi, (l.npi IS NULL) AS not_on_leie
FROM state_inforce s LEFT JOIN leie_inforce l USING (npi)
)
SELECT state,
count(DISTINCT npi) AS excluded_npi,
count(DISTINCT npi) FILTER (WHERE not_on_leie) AS not_on_leie
FROM flagged GROUP BY state ORDER BY excluded_npi DESC;
-- NY 2,259 (1,352 not on LEIE) · PA 973 (568) · OH 673 (363) · IA 313 (263) · MD 264 (222)
-- · WA 210 (178) · NC 149 (128) · MS 138 (106) · NH 51 (37) · ND 47 (28) · MT 42 (16)
-- · GA 35 (8) · TN 9 (8). Sum of per-state distinct NPI = 5,163 state-NPI pairs; distinct
-- across states = 4,949 (the 198 multi-state NPIs are counted once per state here).
-- ── Coverage + the unmatchable majority (rows with no NPI) ──────────────────
-- audit-claim: raw-state-universe
SELECT
count(*) AS total_rows, -- 22,917
count(*) FILTER (WHERE reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14') AS inforce_rows, -- 21,003
count(*) FILTER (WHERE nullif(btrim(npi), '') IS NOT NULL) AS rows_with_npi, -- 5,922
count(*) FILTER (WHERE nullif(btrim(npi), '') IS NULL) AS rows_no_npi, -- 16,995
round(100.0 * count(*) FILTER (WHERE nullif(btrim(npi), '') IS NULL) / count(*), 1) AS pct_no_npi, -- 74.2
count(DISTINCT nullif(btrim(npi), '')) AS distinct_npi, -- 5,224 (incl. reinstated)
count(DISTINCT state) AS states -- 13
FROM public.state_exclusions;
-- 74.2% of state exclusion rows carry no NPI at all. They cannot be matched to a federal
-- list by identifier and are excluded from the matchable denominator, never name-matched.
-- Full federal source universes, separate from the distinct-NPI join sets.
-- audit-claim: federal-source-universes
SELECT
(SELECT count(*) FROM public.oig_leie_exclusions) AS leie_rows,
(SELECT count(*) FROM public.oig_leie_exclusions
WHERE nullif(btrim(npi), '') IS NOT NULL) AS leie_rows_with_npi,
(SELECT count(*) FROM public.sam_exclusions
WHERE status = 'Active'
AND (termination_date IS NULL OR termination_date > DATE '2026-07-14')) AS sam_active_rows,
(SELECT count(*) FROM public.sam_exclusions
WHERE status = 'Active'
AND (termination_date IS NULL OR termination_date > DATE '2026-07-14')
AND nullif(btrim(npi), '') IS NOT NULL) AS sam_active_rows_with_npi,
(SELECT count(DISTINCT btrim(npi)) FROM public.sam_exclusions
WHERE status = 'Active'
AND (termination_date IS NULL OR termination_date > DATE '2026-07-14')
AND nullif(btrim(npi), '') IS NOT NULL) AS sam_active_distinct_npi;
-- LEIE 68,055 rows / 7,025 with NPI
-- SAM 323,930 active rows / 37,443 with NPI / 4,694 distinct NPIThe snapshot
| dataset_id | oig-leie |
| snapshot_date | 2026-07-14 |
The JOINs
join key: state_exclusions.npi = oig_leie_exclusions.npi = sam_exclusions.npi -- 10-digit NPI, btrim, never a name match state / LEIE in_force = reinstatement_date IS NULL OR reinstatement_date > DATE '2026-07-14' SAM in_force = status = 'Active' AND (termination_date IS NULL OR termination_date > DATE '2026-07-14') matchable = distinct in-force state NPI (non-empty); rows with no NPI excluded and reported separately federally_invisible = matchable NPI with NO in-force row in oig_leie_exclusions on the same NPI -- 3,188 / 4,949 = 64.4% invisible_to_both = matchable NPI absent from BOTH oig_leie_exclusions AND sam_exclusions -- 2,997 cross_state = distinct NPI present on 2+ distinct state lists -- 198, max 7
The pipeline version
| methodology_version | state-blind-spot/v1 |
Reproduce this
Run the exact query against the frozen 2026-07-14.
Cite this study
Citation-ready for researchers and AI.
Check the chain
The cited snapshot identifies the federal file. Where an attestation is present, its file hash can be re-derived; figures are not individually signed.
oig-leie · 2026-07-14Not suppliedInspect supplied artifact- FINANCIAL DISTRESS · JUN 2026State Medicaid Exclusion Lists vs the Federal LEIE: The GapIn the July 14, 2026 production observation, 3,188 of 4,949 NPI-identified providers excluded across 13 state Medicaid programs — 64.4% — carried no record on the federal OIG LEIE. Another 15,487 in-force state exclusion records had no NPI and could not be matched to the federal list by identifier.
- FINANCIAL DISTRESS · JUN 2026Barred but billable: excluded providers still enrolled in Medicare19 providers barred from all federal health programs by the OIG still hold an active Medicare enrollment record in PECOS — out of 6,880 in-force NPI-identified federal exclusions. Most trace to a single refresh cycle's lag, but two have stood for over a year, one excluded since 2015.
- FINANCIAL DISTRESS · JUN 2026The OIG exclusion list, explained: who gets barred from Medicare, and whyThe OIG List of Excluded Individuals and Entities (LEIE) holds 68,055 active exclusions spanning 1977–2026. The most common reason to be barred from Medicare is not fraud — it is losing a state license: §1128(b)(4) license actions are 41% of the list. And only 10.3% of records carry an NPI, so the list is mostly non-clinicians.
- FINANCIAL DISTRESS · JUN 2026Industry payments to providers on the OIG exclusion listIn program year 2024, drug and device manufacturers reported $3.84 million in Open Payments to 294 physicians and other providers who now sit on the federal OIG exclusion list, spread across 3,055 separate transfers. A single category — debt forgiveness — accounts for $3.27 million of that total.
- FINANCIAL DISTRESS · JUN 2026OIG Exclusion Check: The 2026 Excluded-Provider LandscapeAt the July 14, 2026 audit cutoff, the OIG LEIE, SAM.gov, and 13 state Medicaid programs contained 10,824 NPI-identified providers barred from a public health program — yet the single most complete list, the OIG LEIE, named only 6,880 of them. Screen against that one source and 36.4% of excluded providers come back clean.
Federal source citations
Fonteum LLC · June 19, 2026 · All figures trace to the frozen federal-data snapshot cited above.