Key Recommendations:
- Pre-Employment and Pre-Engagement Checks: Review the OIG database before offering employment or establishing a business relationship with any individual or vendor.
- Periodic Verification: Conduct regular internal audits to ensure that existing staff and contractors remain clear of the OIG Exclusion List.
- Documentation: Maintain records of all verifications as part of routine compliance monitoring.
Potential Consequences of Non-Compliance:
Hiring or contracting with an excluded individual in connection with federal program services may result in civil monetary penalties or other administrative actions. Regular verification helps protect the practice and supports ongoing compliance efforts.




