What a SAM exclusion is and how it differs from the OIG list

A SAM exclusion is a record on the SAM exclusion list in SAM.gov, the System for Award Management run by the General Services Administration (GSA) (FAR 9.404). It can show debarment, suspension, proposed debarment, a voluntary exclusion or another restriction (FAR 9.405, exclusion types). Those types do not all bar the same transactions, so read the record before you treat a transaction as blocked.

That list is not the HHS OIG List of Excluded Individuals/Entities (LEIE). SAM includes actions by many federal agencies, including OIG. The LEIE holds only OIG actions (OIG FAQ).

What a SAM exclusion record contains

Federal agencies, HHS OIG included, enter their own exclusions within 3 working days after the action takes effect, voluntary exclusions included (FAR 9.404). A January 2025 final rule added voluntary exclusions to that section. It took effect on January 17, 2025. Under the same section, each record shows:

• the excluded party's name and address, with cross-references
• the agency that took the action
• the cause or legal authority, and the effect
• the termination date
• the Unique Entity Identifier (UEI)
• the SSN, EIN or other TIN, where available
• an agency contact name and phone number

SAM sorts every record into one of four exclusion types: Ineligible (Proceedings Pending), Ineligible (Proceedings Completed), Prohibition/Restriction (Treasury OFAC sanctions, for example) and Voluntary Exclusion. These four replaced about 71 "Cause and Treatment" codes from the old Excluded Parties List System (EPLS).

FAR 9.405 sets procurement limits for contractors that are debarred, suspended, proposed for debarment or voluntarily excluded. Agencies may not solicit offers from them, award them contracts or consent to subcontracts with them, unless the agency head finds a compelling reason. Contracting officers check SAM exclusions after offers open and again right before award.

Exclusion also crosses over between contracts and grants. A debarment or suspension under the procurement rules also excludes the party from nonprocurement transactions such as grants and cooperative agreements, and the reverse is true too, for actions on or after August 25, 1995 (FAR 9.401, 2 CFR 180.140).

How to search SAM.gov exclusions

You don't need a SAM.gov login. GSA's Federal Service Desk says "You do not need to be signed into SAM.gov to search exclusions". Go to Search, then Entity Information, then Exclusions, or open the exclusions search page directly.

The public search shows only active exclusions, so an exclusion that has ended won't appear.

For bulk screening, GSA publishes a daily Exclusions Extract of every party with an active exclusion. Downloading it through the API, or using the Exclusions API, needs a registered SAM.gov account and an API key.

How the OIG and GSA exclusion lists differ

HHS OIG excludes people and entities under sections 1128 and 1156 of the Social Security Act (exclusions FAQ, updated April 30, 2026). The LEIE holds only OIG's own exclusion actions. SAM "contains debarment actions taken by various Federal agencies, including exclusion actions taken by OIG."

So SAM carries OIG exclusions, yet OIG still points you to the LEIE. Its 2013 Special Advisory Bulletin on the Effect of Exclusion calls the LEIE the primary source for OIG exclusions, because it holds more detail, such as date of birth, occupation and the statutory basis.

The LEIE comes as an online search and as a downloadable CSV with monthly supplements. The OIG FAQ says both versions are "generally updated by the middle of each month" with the prior month's actions. A name match in the download isn't proof. OIG asks you to confirm it by entering the SSN for an individual, or the EIN for an entity, in the online search.

For healthcare providers, the OIG payment ban is the main concern. No federal health care program pays for items or services furnished by an excluded person, or at the direction or on the prescription of an excluded person (42 CFR 1001.1901). A provider risks a civil money penalty for employing or contracting with someone it knows or should know is excluded. This applies when that person provides items or services payable by a federal health care program (42 CFR 1003.200(b)(4)).

The regulation sets the base at up to $20,000 per item or service, plus an assessment of up to three times the amount claimed (42 CFR 1003.210). The adjusted maximum is $25,595 per item or service (45 CFR 102.3). The January 28, 2026 adjustment applies to penalties assessed on or after that date. The 2013 OIG bulletin still quotes $10,000. That figure is out of date.

A SAM listing by another agency is different. OIG's bulletin also says "OIG has no authority to impose CMPs on the basis of employment of (or contracting with) a debarred person." Even so, a clean SAM result does not clear the LEIE, and a clean LEIE result does not clear SAM. Neither list includes a state Medicaid exclusion list. Check one if your provider agreement requires it.

Who must check SAM, the LEIE or both

No single federal rule tells every healthcare employer to check these lists. OIG's 2013 bulletin says providers "are not required by statute or regulation to check the LEIE." It still advises monthly checks, because that is the best way to limit overpayments and penalty exposure. The duty to check comes from several places instead.

State Medicaid agencies have a hard rule. Under 42 CFR 455.436 they must check the SSA Death Master File, NPPES, the LEIE and the EPLS for providers and their owners, agents and managing employees. The LEIE and EPLS checks happen at least monthly. The rule still says EPLS, which today means SAM.gov exclusions.

Medicare Advantage and Part D sponsors follow CMS manual guidance. Section 50.6.8 of Medicare Managed Care Manual Chapter 21 and Prescription Drug Benefit Manual Chapter 9 call for both LEIE and EPLS checks. Sponsors must review both before hiring or contracting, then monthly. This covers employees, temporary staff, volunteers, consultants, governing body members and first-tier, downstream or related entities (FDRs).

That screening instruction is CMS manual guidance. The underlying compliance program requirements are 42 CFR 422.503(b)(4)(vi) for MA and 423.504(b)(4)(vi) for Part D. Separately, MA plans may not pay OIG-excluded individuals or entities (42 CFR 422.224).

For a federal debarment check, contracting officers follow FAR 9.405. Participants in covered grants and other nonprocurement transactions have alternative ways to verify eligibility. Before entering a covered transaction with a lower-tier party, they must verify it isn't excluded by checking SAM.gov Exclusions, collecting a certification or adding a clause to the transaction (2 CFR 180.300). HHS adopts the government-wide nonprocurement rule, 2 CFR 180, at 2 CFR part 376.

For hospitals, physician groups and pharmacies, OIG recommends monthly LEIE screening to reduce penalty exposure. Screen at hire as well as monthly. Providers that act as FDRs in MA or Part D networks should check their plan contracts for LEIE and SAM screening duties.

What happened to EPLS

EPLS, the Excluded Parties List System, was GSA's old federal debarment list. A FAR rule of January 3, 2012 set up the move to SAM. GSA launched SAM Phase 1 on July 29, 2012, which folded CCR, ORCA and EPLS into one system and retired the old ones (Federal Register, 2013). So an "EPLS search" or "GSA exclusion list" check today means searching SAM.gov exclusions. That's also how you meet older rules, like 42 CFR 455.436 and the CMS manual, that still name EPLS. RegAffairs AI's answer page covers the SAM vs OIG question, with citations to these rules.

Changes to watch

As of October 8, 2026, two proposals could change these rules. A September 18, 2026 FAR overhaul proposed rule covering Parts 9, 27 and 47 keeps 9.404 with small wording edits. Comments close October 19, 2026. An OMB proposed rule on federal financial assistance from May 29, 2026 would revise 2 CFR 180, including section 180.530 on where to find SAM.gov Exclusions. Its comment period closed on July 13, 2026.