OIG Exclusion Patterns: Who Gets Barred from Medicare

The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services maintains the List of Excluded Individuals/Entities (LEIE). Federal law (42 U.S.C. § 1320a-7) requires or permits the OIG to exclude individuals and entities from participation in Medicare, Medicaid, and other federal healthcare programs under two main tracks:

Mandatory exclusions (§1128a): triggered by criminal convictions related to healthcare program fraud (§1128a1), patient abuse or neglect (§1128a2), felony healthcare fraud (§1128a3), or felony controlled-substance offenses (§1128a4). Minimum exclusion period is 5 years for the §1128a categories; 10 years for repeat offenders.

Permissive exclusions (§1128b): a broader category covering license revocations (§1128b4), misdemeanor convictions related to program fraud (§1128b1), default on federal health education loans (§1128b14), making false statements (§1128b8), and about a dozen other statutory bases. The OIG exercises discretion on whether to exclude and for how long.

Providers, plans, and hospitals are required by CMS to check the LEIE before hiring or contracting. Employing an excluded individual in a Medicare/Medicaid billing context can result in civil monetary penalties.

Source: OIG LEIE exclusion list — public federal dataset, snapshot 2026-05-25.

The 68,055 records in the 2026-05-25 snapshot distribute across statutory categories as follows (top 8 by volume):

The §1128b4 dominance is structurally significant: state license revocation is the most common trigger because it captures all professions (physicians, nurses, pharmacists, billing agents, equipment suppliers) and the state action automatically produces a federal exclusion. §1128a1 convictions (program-related fraud) are the largest mandatory-exclusion category.

Numbers confirmed 2026-05-25 via direct query on oig_leie_exclusions.

Only 10.3% of the 68,055 exclusion records carry a National Provider Identifier (NPI) — approximately 7,010 records. This is a consequential fact for anyone building compliance tooling:

The LEIE is not a physician-only list. It covers any individual or entity that participates in federal healthcare programs in any capacity: licensed clinicians, but also:

• Durable medical equipment (DME) suppliers
• Home health aides and personal care attendants
• Billing agents and coding staff
• Pharmacy technicians
• Nursing home administrators and owners

NPIs are issued by CMS to licensed practitioners and certain entities — they are not issued to most non-clinical billing staff, suppliers, or administrative personnel. The 89.7% of records without an NPI are not necessarily physicians who lost their identifier; they are mostly parties who never had one.

Compliance implication: Matching the LEIE only against NPI is insufficient. The OIG recommends also matching against SSN, EIN, DOB, and address fields. The 10.3% NPI coverage rate in this dataset is consistent with prior academic estimates of the non-clinician share of the excluded population.

California leads all states with 7,896 exclusions — 11.6% of the national total. The state concentration reflects both population size and enforcement intensity; California also has one of the largest Medi-Cal (state Medicaid) programs, which generates proportionally more fraud referrals.

State concentration in the LEIE is a function of:

1. Population. Larger states have more providers and more billing volume, producing more referral opportunities.
2. Medicaid program size. States with large Medicaid rolls generate more OIG referrals from state-level fraud control units (MFCUs).
3. State licensing board activity. §1128b4 records originate from state license revocations; states with active licensing boards surface more revocations to OIG.

The 11.6% California share does not imply that California providers are more likely to commit fraud per capita — it reflects the interaction of all three factors above.

• Snapshot date. Numbers reflect the OIG LEIE as ingested on 2026-05-25. The OIG publishes monthly updates; totals change as new exclusions are added and reinstatements are processed.
• Active vs cumulative. The LEIE is a list of currently active exclusions, not a cumulative historical count. Reinstated parties are removed from the published list.
• NPI match is approximate. The ~10.3% NPI match rate reflects the share of records with a non-null NPI field in the OIG's published data — it does not imply that the other 89.7% lack NPIs; some may have NPIs that OIG did not record in the exclusion row.
• Statutory category counts. One exclusion record maps to one primary statutory basis. A party may have been subject to multiple underlying violations; only the OIG-designated primary exclusion basis is reported here.
• No claim about individual providers. This study is aggregate-only. No individual exclusion records are surfaced, recommended, or attached to any provider profile in this dataset.
• Not a quality metric. Exclusion counts are a compliance and enforcement signal, not a quality measure. A low exclusion count in a state does not mean its providers are more ethical; it may reflect enforcement patterns or population size.

Source. OIG LEIE exclusion list — public federal dataset, updated monthly by the U.S. Department of Health and Human Services Office of Inspector General. The full LEIE is available at oig.hhs.gov/exclusions/exclusions_list.asp.

Ingestion. OIG LEIE records were ingested into the oig_leie_exclusions table via the §sprint1-oig-leie-sanctions wave operator script. The ingest parses the OIG-published bulk CSV, normalizes statutory codes, and upserts into Supabase with RLS Pattern B (public read, writes denied).

Aggregation. All counts in this study were computed via direct SQL query on oig_leie_exclusions on 2026-05-25. Statutory category counts use the exclusion_type field as published by OIG. NPI match rate uses npi IS NOT NULL condition. State counts use the state field from the OIG record.

Doctrine. Tier-2 research snapshot under doctrine v1.6 LOCKED-HEALTHCARE-ONLY-SCOPE. OIG LEIE is cross-vertical (covers all healthcare-billing entities). No individual exclusion records are surfaced in provider profiles in this snapshot wave.