To ensure compliance and patient safety, there are two federal sources that healthcare organizations need to screen for exclusions at a minimum monthly, as well as State Medicaid exclusion lists. The two major federal sources that need to be continuously monitored are the Department of Health and Human Services (HHS) Office of Inspector General (OIG) List of Excluded Individuals/Entities (LEIE) and SAM.gov. The primary difference between the OIG LEIE and SAM.gov is that the former only consists of exclusion actions taken by the HHS OIG, and the latter consists of debarment actions taken by various Federal agencies.
Read on for a summary of one of the main primary sources: SAM.gov.
What is SAM.gov?
The SAM.gov database is formerly known as the Government Services Administration's (GSA) Excluded Parties List System (EPLS). In 2012, GSA announced it was migrating data from the EPLS to a more comprehensive system called the System for Award Management (SAM). Formed under a mandate of the Affordable Care Act, SAM.gov created one broader dataset of individuals and entities that are debarred, sanctioned, or excluded from doing business under a federal contract. The most significant database for healthcare providers, SAM.gov includes several federal contracting databases such as USDA-FNS, TREAS-OFAC, OPM, and more.
If an individual or entity is on SAM.gov, a healthcare company should not be in contractual privity with such person or company as it would be conducting business with a sanctioned, debarred, or excluded party. HHS OIG and the Centers for Medicare and Medicaid Services (CMS) have both made it clear that federal program payment for (1) items or services furnished by excluded individuals or entities, and (2) salaries, expenses, or fringe benefits of excluded individuals (regardless of whether they provide direct patient care) are prohibited. SAM.gov datasets should be included in all exclusion screening processes for employed and contracting populations.
What Authority Does SAM.gov Have?
SAM.gov does not have the authority to penalize an organization like the HHS OIG does, but instead is a procurement repository. If an organization is debarred, it might not mean that you cannot do business with them. If your organization does not require your vendor to be GSA approved nor is it being reimbursed through federal program dollars, the debarment may not affect your contract (this must be reviewed by your legal counsel).
As of July 2021, the SAM.gov database has more than 70,000 excluded individuals and entities. Check out ProviderTrust's interactive exclusion map for up-to-date numbers.
What Did the Recent SAM.gov Updates Entail?
On May 24, 2021, SAM.gov rolled out a brand new user interface and a reorganization of the site. According to SAM.gov, their updates "incorporate customer-focused functionality changes to improve the overall experience for site visitors" and include a streamlined advanced search experience and more. However, the update to SAM.gov caused some confusion across the industry.
According to ProviderTrust Partner & Co-Founder, Mike Rosen, regarding the SAM.gov updates, "People need to be aware it will look very different and will be searched very differently."
At ProviderTrust, as a compliance monitoring industry leader, it was vital that our team understand where and how to access the data that we consistently download from SAM.gov. We also needed to understand if the format of the data was changing in any way and if there were any restrictions regarding accessing the data. Although it was initially difficult to access the SAM.gov documentation regarding the changes, once we were able, the process to update our own documentation was straightforward.
If you’re one of the compliance professionals that's been struggling with the recent SAM.gov updates, read through our one-pager for tips on how to search for an excluded individual using their Social Security number.
Could your organization use some help with continuously monitoring the OIG LEIE, State Medicaid exclusion lists, and SAM.gov to ensure compliance across your populations? Explore our Exclusion Monitoring Solution Guide.