Provider and Entity Transparency with the SAM Database

In 2019, total federal program spending was 19% of GDP for the United States. That number is set to rise an additional 1% over the next 10 years as demand for Social Security, Medicare, and other entitlement programs grow. That means that doing business with the federal government taps into a market of nearly one-fifth of the entire U.S. economy. In health care, that’s an especially big portion of the pie since Medicare and Social Security account for 8% of federal spending alone.

Since doing business with the federal government involves taxpayer money and a strict accountability to Congress, there are specific procedures to follow to be eligible for federal procurement systems. Here’s how one of those procedures, the System for Award Management (SAM) works, what it is, and why it matters for identifying health care providers.

What is SAM and who manages it?

According to its official website, SAM is a free website where entities can:

• Register to do business with the U.S. government
• Update or renew their entity registration
• Check the status of an entity registration
• Search for entity registration and exclusion records

SAM is managed by the General Services Administration (GSA) and is a consolidated database that any department of the federal government now uses for procurement. So, while the Centers for Medicare and Medicaid (CMS) use SAM for procurement, they are certainly not the only department to do so.

What is the SAM exclusion record?

One of the other important functions of SAM, beyond providing a centralized way for payments and awards to be approved and managed, is adding individuals to an exclusion record.

According to SAM, “Exclusion records identify those parties excluded from receiving federal contracts, certain subcontracts, and from certain types of federal financial and non-financial assistance and benefits. These are also commonly known as ‘suspensions’ and ‘debarments.’”

The exclusion list protects the federal government and taxpayers from fraud and abuse with a centralized system for agencies and departments that know which individuals and contractors have proven themselves to not be responsible stewards of public money.

According to GSA, the causes for a suspension or debarment include:

• Commission of fraud, embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, tax evasion, violating Federal criminal laws, receiving stolen property, an unfair trade practice
• Violation of antitrust statutes
• Willful, or a history of, failure to perform
• Violation of the Drug-Free Workplace Act
• Delinquent Federal taxes (more than $3,000)
• Knowing failure to disclose violation of criminal law
• Any other cause that affects present responsibility

Once an individual or entity is suspended or debarred, their name is published on the SAM website and the effects reach the federal government for both procurement and non-procurement programs. Contracts shall not be awarded to a suspended or debarred individual or entity.

Understanding the differences between LEIE and SAM

For health care entities, the Department of Health and Human Services (HHS) has a separate list of exclusions called the List of Excluded Individual and Entities. This list is maintained by HHS and “provides information to the health care industry, patients and the public regarding individuals and entities currently excluded from participation in Medicare, Medicaid and all other Federal health care programs.”

One of the most obvious differences between SAM and LEIE is the agency that administers them. SAM is administered by GSA and the LEIE is administered by HHS.

However, as mentioned before, SAM is a broader database that includes registrations from all individuals and entities doing business with the federal government. It includes active, pending, and disbarred or suspended registrants — including those made by the Office of the Inspector General (OIG). The LEIE is only a list of exclusions from the OIG.

Entities and individuals found on the LEIE and SAM can pose a serious risk to patients as well as legal and reputational risk to the organizations that hire and retain them. Screening against SAM is just another tool among many that organizations can use to search for potential red flags. Using this data along with other databases gives a comprehensive picture and allows organizations the best chance at detecting practitioners who are skilled in evading detection.

SAM is one of the more than 5,000 data sets that Verisys uses as part of our data platform, allowing organizations a singular view into thousands of records and entities. This data protects your organization and patients from bad actors simply and effectively.

Written by Heather Lynn Gillman Director of Healthcare Communications Problem Solver. Designer. Wine Maker. Writer. Connect with Heather on LinkedIn