The Department of Health and Human Services Office of Inspector General (HHS-OIG) has released its monthly update to the List of Excluded Individuals and Entities (LEIE) for June 2026. For Covered Entities, Business Associates, and their security teams, this is not merely administrative housekeeping—it is a critical compliance trigger.
Employing or contracting with an individual or entity on the LEIE can result in Civil Monetary Penalties (CMPs) of up to $10,000 per claim, assessment liability, and potential exclusion from federal healthcare programs like Medicare and Medicaid. As senior consultants, we emphasize that effective defense includes not just technical controls but rigorous internal governance to prevent unauthorized access or billing by sanctioned parties.
Technical Analysis
The Risk Vector
The LEIE update effectively functions as a "deny-list" for the healthcare sector. New exclusions typically result from convictions for program-related fraud, patient abuse or neglect, licensure revocation, or default on health education loan repayments.
- Affected Platforms: Administrative systems, HR databases, and Electronic Health Records (EHR) systems containing workforce and vendor data.
- Mechanism of Impact: If an excluded individual performs services directly or indirectly (e.g., through a contracted agency) that are billed to federal healthcare programs, the payments are considered "overpayments" that must be reported and returned.
- Current Status: The June 2026 update adds new entries to the "Mandatory" (permissive exclusion under Section 1128(b)) and "Permissive" (mandatory exclusion under Section 1128(a)) exclusion lists.
Why This Matters for Security & IR
From a Digital Forensics and Incident Response (DFIR) perspective, compromised credentials of an employee who is later placed on the LEIE complicate attribution and legal liability. Furthermore, threat actors often exploit the chaos of contractor turnover. Ensuring immediate deprovisioning of access for excluded individuals is a mandatory security control.
Executive Takeaways
- Implement Continuous Monitoring: Do not rely on manual monthly checks. Integrate the LEIE download into your Identity and Access Management (IAM) workflows to automate screening against current and new hire lists.
- Audit Vendor Rosters Immediately: Request updated exclusion attestation from all staffing agencies and Business Associates (BAs) this week. Verify that no sub-contractors added in June 2026 appear on the new LEIE.
- Review Claims for June 2026: Conduct a retrospective analysis of claims submitted by current staff and vendors. If anyone on your team was added to the list in June 2026, you may have generated overpayments that require self-disclosure to the OIG within 60 days.
- Enforce Offboarding Procedures: Ensure that HR termination feeds trigger immediate revocation of EHR, VPN, and email access. An excluded individual retaining access is a reportable compliance violation and a security risk.
Remediation Script
The following PowerShell script is designed to be run by Security Operations or Compliance teams. It downloads the current LEIE from the official HHS source and compares it against a local CSV of employees or vendors (which you must generate from your HR system).
# HHS-OIG LEIE Screening Script
# Purpose: Download current LEIE and compare against local employee/vendor list
# Usage: Update the $LocalListPath variable to point to your internal HR export (CSV)
$LocalListPath = "C:\Secure\HR\current_staff.csv"
$LeieUrl = "https://oig.hhs.gov/exclusions/exclusions_list.csv"
$LeieOutputPath = "$env:TEMP\LEIE_Update.csv"
$ResultsPath = "C:\Secure\Audit\Exclusion_Matches_$(Get-Date -Format 'yyyyMMdd').txt"
# Function to download the latest LEIE
function Get-LeieData {
Write-Host "[*] Downloading current LEIE from HHS-OIG..." -ForegroundColor Cyan
try {
Invoke-WebRequest -Uri $LeieUrl -OutFile $LeieOutputPath -ErrorAction Stop
Write-Host "[+] LEIE downloaded successfully." -ForegroundColor Green
}
catch {
Write-Host "[-] Error downloading LEIE: $_" -ForegroundColor Red
exit
}
}
# Function to perform screening
function Start-Screening {
if (-not (Test-Path $LocalListPath)) {
Write-Host "[-] Error: Local list not found at $LocalListPath" -ForegroundColor Red
return
}
Write-Host "[*] Importing Local Staff Data..." -ForegroundColor Cyan
# Assuming HR CSV has headers 'FIRSTNAME', 'LASTNAME', 'NPI', 'DOB'
$LocalStaff = Import-Csv -Path $LocalListPath
Write-Host "[*] Importing LEIE Data..." -ForegroundColor Cyan
# LEIE CSV is fixed-width/text-based, but usually parsed as CSV with relevant columns
# Columns: LASTNAME, FIRSTNAME, BUSINESSNAME, NPI, etc.
$LeieData = Import-Csv -Path $LeieOutputPath
$MatchesFound = 0
$ReportContent = @()
Write-Host "[*] Cross-referencing staff against LEIE..." -ForegroundColor Cyan
foreach ($Person in $LocalStaff) {
# Normalizing strings for comparison
$LName = ($Person.LASTNAME).Trim().ToUpper()
$FName = ($Person.FIRSTNAME).Trim().ToUpper()
$NPI = ($Person.NPI).Trim()
# Check against LEIE
$Match = $LeieData | Where-Object {
($_.LASTNAME -eq $LName -and $_.FIRSTNAME -eq $FName) -or
($_.NPI -eq $NPI -and $_.NPI -ne "")
}
if ($Match) {
$MatchesFound++
$Details = "MATCH FOUND: $($Person.FIRSTNAME) $($Person.LASTNAME) | NPI: $($Person.NPI) | EXCLUSION TYPE: $($Match.EXCLTYPE)"
Write-Host "[!] $Details" -ForegroundColor Red
$ReportContent += $Details
}
}
# Output Report
if ($MatchesFound -gt 0) {
$ReportContent | Out-File -FilePath $ResultsPath
Write-Host "[+] Critical: $MatchesFound potential matches found. Report saved to $ResultsPath" -ForegroundColor Red
Write-Host "[!] ACTION REQUIRED: Immediately verify identity and terminate access if confirmed." -ForegroundColor Red
}
else {
Write-Host "[+] No matches found against current LEIE." -ForegroundColor Green
}
}
# Execute
Get-LeieData
Start-Screening
# Cleanup
Remove-Item $LeieOutputPath -ErrorAction SilentlyContinue
Remediation Steps
- Immediate Verification: If the script or manual check identifies a potential match, verify the identity using the Unique ID (SSN/EIN) or NPI to avoid false positives.
- Terminate Access: Immediately revoke all system access (Active Directory, EHR, Remote Desktop, VPN) for any confirmed excluded individual.
- Financial Review: Review all claims submitted by or involving the excluded individual during the period they were employed/contracted while excluded.
- Report Overpayments: If claims were submitted after the exclusion date, you must identify and return the overpayment. The OIG Self-Disclosure process should be initiated if the aggregate overpayment exceeds $10,000.
- Policy Update: Update your Sanction Screening Policy to mandate weekly automated checks rather than monthly, reducing the window of exposure.
Related Resources
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