Industry payments to providers on the OIG exclusion list

The federal List of Excluded Individuals and Entities — the OIG LEIE — names the providers barred from billing Medicare, Medicaid, and every other federal health program. The exclusion is a financial wall: a federal program cannot pay an excluded party, directly or indirectly. But the wall is one-directional. It says nothing about money flowing the other way — from drug and device manufacturers to the provider. This study measures that flow.

It joins the CMS Open Payments file — the manufacturer-reported registry of transfers of value to physicians and teaching hospitals, mandated by the Physician Payments Sunshine Act — against the OIG LEIE on the National Provider Identifier, and asks a single question: how much did industry pay to providers who now sit on the federal exclusion list?

The match, in one number

In program year 2024, manufacturers reported $3,835,221 in Open Payments to 294 providers who now appear on the federal OIG LEIE, across 3,055 separate transfers. That is the headline: $3.84 million, in a single program year, to individuals the federal government has since barred from its own health programs.

The 294 providers are 4.3% of the 6,880 NPI-identified individuals on the LEIE — roughly one in twenty-three. The join is strictly on the 10-digit NPI; a name is never used to assert a match. The figure counts every matched transfer of value in the file, regardless of when it was dated relative to the exclusion, and it is a disclosure record, not an allegation. The sections below separate the money by category, by manufacturer, and — crucially — by whether the payment predates or postdates the exclusion itself.

Most of the money is one line item

$3.27 million of the $3.84 million — 85.1% — is a single payment category: debt forgiveness. Eleven providers account for all of it, across just 29 records.

The concentration is sharper at the manufacturer level. One orthobiologics maker, Skye Orthobiologics, reported $3,196,265 in just two debt-forgiveness records — 83% of every dollar in this analysis. Debt forgiveness is what it sounds like: a manufacturer writing off money a provider owed it. At this scale it reads less like a marketing touch and more like the unwinding of a commercial relationship, which is itself the kind of fact that belongs on the public record. The next-largest payer, CSL Plasma, reported $389,671 — but across 439 separate records, a very different shape of relationship.

The breadth: a meal for nearly every provider

While the dollars concentrate, the contact does not. Food and beverage reached 274 of the 294 excluded providers — 93% of them — across 2,460 records, for a modest $64,589 in total. This is the texture of routine industry detailing: the catered lunch, the conference coffee, recorded one provider at a time.

An exclusion bars a provider from billing federal health programs. It does not stop the checks from industry — $3.84 million reached 294 barred providers in a single program year.

By reach, AbbVie touched the most excluded providers, 78 of them, almost entirely through these small transfers — its 351 records average about $34 each. The pattern matches what we found looking at how industry payments break down by category across the whole file: a few enormous line items carry the dollars, while food and beverage carries the relationships. Among providers later excluded, both halves of that pattern are present.

Payments dated after the exclusion

$209,758 across 855 payments carries a payment date after the provider's OIG exclusion had already taken effect — reaching 181 of the 294 providers. The remaining $3,625,464, including the entire $3.27 million in debt forgiveness, is dated on or before the exclusion date.

The post-exclusion slice is small in dollars and concentrated in food-and-beverage transfers, which is what one would expect: detailing relationships have inertia, and a lunch logged a few weeks after an exclusion is more plausibly an un-updated call list than a deliberate act. But it is the more pointed half of the finding. An exclusion is a published federal event; a manufacturer's compliance screening is supposed to catch it. That 181 providers still appear as paid contacts after their exclusion date is a measurable seam between two systems that are meant to be aligned — the same kind of seam we documented in the lag between a termination event and CMS deactivation.

What an Open Payments record does and does not mean

A transfer of value reported under the Sunshine Act is a disclosure, not a verdict. The Sunshine Act requires manufacturers to report nearly every payment or item of value given to a covered recipient; it attaches no judgment about that payment's propriety. An OIG exclusion, separately, bars the provider from being paid by federal health programs — it does not bar a manufacturer from buying them lunch or forgiving a debt, and it does not make the disclosure itself improper.

So this study is not an allegation of fraud against any provider, and it names none. It is a structural observation: the population that industry pays and the population the federal government excludes overlap, by $3.84 million in a single year, and the public record lets anyone trace exactly where. The reason that overlap is worth surfacing is the same reason both registries exist — they are the federal data layers that let a journalist, a compliance officer, or a payer see a provider from two independent angles at once. Read together they are far more informative than either alone, which is the broader point of who actually gets barred from Medicare and why.

The unmatchable majority

This analysis can only see excluded providers who carry an NPI. Of the 68,055 records on the OIG LEIE, only 7,025 carry an NPI at all — 6,880 distinct individuals — and the remaining 61,030 records name an excluded party with no identifier that maps to the Open Payments file.

These 61,030 records are excluded from the matchable denominator, not folded into it, because matching them to a payment would require a name match — and a name match is not a defensible identity assertion. The same NPI-sparsity is a known limitation of the LEIE itself, documented in the state Medicaid bars that federal screening never sees. The practical consequence is blunt: $3.84 million is a floor, computed against the 6,880 excluded providers we can identify by number. Any industry payments to the 61,030 NPI-less exclusion records are invisible to this join and are neither counted nor estimated.

Methodology

Every figure is a direct NPI join between two public Postgres tables: cms_open_payments (the CMS Open Payments general, research, and ownership records for program year 2024, manufacturer-reported under the Physician Payments Sunshine Act) and oig_leie_exclusions (the OIG monthly LEIE bulk download, release 2026-05-08, 68,055 active records). Both tables are RLS Pattern B — public read.

The join key is recipient_npi = npi, both trimmed of whitespace; a name is never used to assert a match. The excluded set is the distinct, in-force NPI population on the LEIE — in force meaning the reinstatement date is null or still in the future, the same test the production exclusion lookup applies. Because the OIG removes reinstated parties from the published file, that set equals every LEIE NPI on record. Dollar totals sum total_amount_usd over matched records; the timing split compares each record's payment_date against the earliest excl_date recorded for that NPI. The exact SQL is in the reproducibility block below, and the provenance methodology documents the row-level signing contract. Methodology version: industry-payments-exclusions/v1.

The figures here are reproducible from two named CMS and OIG primary sources, and every number resolves to specific rows in specific frozen snapshots — the same chained-provenance contract carried by every Fonteum study. The underlying tables are browsable at the CMS Open Payments data page and the federal OIG LEIE data page.

Limitations

• One program year. The ingested Open Payments snapshot covers program year 2024. The $3.84 million describes that year alone; earlier years are not yet in the file and are not estimated.
• NPI is the floor, not the ceiling. 61,030 LEIE records carry no NPI and cannot be matched to a payment by identifier; they are reported separately, never guessed at by name. The matched total is a floor over the 6,880 identifiable excluded providers.
• A disclosure, not a verdict. An Open Payments record is a manufacturer's required disclosure of a transfer of value. It is not evidence of an improper payment, and an OIG exclusion does not prohibit such transfers. No individual provider is named, surfaced, or alleged to have done anything wrong in this study.
• Timing is reported, not adjudicated. The before/after split compares payment dates to exclusion dates as recorded. A payment dated after an exclusion is a data fact about a seam between two federal systems, not a determination that any party violated a screening obligation.
• Snapshot, not cumulative. Both files are point-in-time. The Open Payments file and the LEIE release shift over time; these figures reflect the current ingested snapshots and will move as both refresh.

Sources

• CMS Open Payments — search tool and annual data downloads — the manufacturer-reported registry of transfers of value, the dollar side of this analysis.
• OIG LEIE — online database and monthly downloads — the federal exclusion list and the comparison anchor.
• OIG — effect of an exclusion (no federal payment, directly or indirectly) — the scope and limits of what an exclusion bars.
• 42 U.S.C. § 1320a-7 (Social Security Act § 1128) — the federal exclusion statute.
• 42 U.S.C. § 1320a-7h (Physician Payments Sunshine Act) — the statute requiring manufacturers to report transfers of value.