Query the OIG's List of Excluded Individuals/Entities (LEIE) — 83,440 records spanning 1977 to 2026 — and one number stands out: 39.9% of all exclusions carry the code 1128b4 (license revocation, suspension, or surrender), making it the single largest individual category in the entire list, ahead of Medicare/Medicaid fraud convictions (1128a1, 30.9%). Add patient-abuse convictions (1128a2, 9.7%) and other felony healthcare-fraud convictions (1128a3, 7.0%), and the three "hard fraud" mandatory-exclusion codes combined (47.7%) actually outnumber the license-based permissive exclusion code alone (39.9%) — so 1128b4's lead only holds category-by-category, not once the mandatory-exclusion codes are pooled. Nurses and nurse's aides are the single largest specialty group excluded (34,644 records, 41.5% of the list) — far ahead of physicians, pharmacists, or DME suppliers combined.
The mechanism: state boards feed the federal list
Section 1128 of the Social Security Act splits exclusions into two tracks. Mandatory exclusions (the 1128a codes) follow a criminal conviction — Medicare/Medicaid fraud, patient abuse, felony controlled-substance offenses — and require a minimum five-year bar. Permissive exclusions (1128b codes) let HHS-OIG exclude someone for reasons that never touch a courtroom, and 1128b4 specifically is triggered whenever a state licensing board revokes, suspends, or accepts the surrender of a license "for reasons bearing on professional competence, professional performance, or financial integrity." Every state nursing board, pharmacy board, and medical board that pulls a license effectively feeds OIG's exclusion pipeline — which is why nurse's aides and CNAs, who churn through state licensing discipline (often for diversion, falsifying records, or abuse findings that never reach criminal charges) so heavily, dominate the raw count. It's a volume artifact of *how* the healthcare workforce is regulated, not evidence that nursing is the epicenter of fraud.
What this means for HCP due diligence
A company screening vendors or hires against LEIE only for "fraud" hits is checking roughly half the list at best. The other, larger share — license discipline, program-related convictions unrelated to false claims, ownership/control ties to already-excluded entities (1128b8, DME suppliers particularly, at 1,485 records) — are equally exclusionary under 42 U.S.C. §1320a-7 and equally capable of triggering CMP liability for any Medicare/Medicaid-participating employer that keeps an excluded person on payroll, per OIG's own guidance.
A named example: the CVS pharmacist ownership route
Ownership and control exclusions (1128b8) — barring anyone with an ownership or controlling interest in a sanctioned entity — are a smaller slice (1,485 records) but disproportionately relevant to corporate diligence, since DME suppliers and home health agencies are named specialties (952 and 1,454 records respectively). OIG has separately flagged this pathway in enforcement actions against pharmacy owners who kept operating through shell entities after individual exclusion, a pattern documented in OIG's own Special Advisory Bulletin on the effect of exclusion.
Caveats
LEIE is a name-and-date list, not a resolved entity graph — the index carries no NPI for most historical records, so matching to a specific clinician requires fuzzy name/DOB/state matching, a known false-positive risk OIG itself warns about. Reinstatement dates exist but many are blank, meaning a "still excluded" read from raw exclusion_date alone can be stale. And the list only reflects federal program exclusions — it says nothing about state Medicaid-only exclusions, which run on a parallel, less complete set of state registries.
Why this matters: as more healthcare AI, staffing, and revenue-cycle vendors build automated credentialing checks, treating LEIE as a "fraud list" undercounts risk substantially, since license discipline alone is the single largest reason for exclusion. The bigger, faster-moving signal is license discipline — which means credentialing pipelines that only refresh against LEIE monthly, without also pulling state board actions in near-real time, are structurally behind the exclusion curve, not ahead of it.