♦ What does it mean if a person is on the OIG or SAM exclusion list?

The OIG and SAM exclusion lists are published by the federal government and contain individuals that have been excluded from doing business with the federal government for one reason or another.  A person that has been convicted of Medicare fraud, for example, may have had to be included on the OIG exclusion list.  Similarly, a person who has been convicted of government fraud in a GSA contract could be on the SAM exclusion list.

So what do you do then?  You need a policy to answer that question.  While MPC cannot tell you what to do exactly, it is common to have an employment, new-hire question asking each new-hire if they are on the OIG or SAM exclusion list, and, for example, making it a condition of employment that employees not be on either of those exclusion lists.

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