OIG LEIE Healthcare Exclusion Reinstatement Application

The situation

Maria worked as a medical billing specialist at a home health agency for 6 years. In 2019 she was named in a False Claims Act investigation, the agency had been billing Medicare for services not rendered. Maria never personally submitted the fraudulent claims but was in the billing department, and she accepted a civil settlement for $8,500 rather than contest a costly federal investigation. OIG excluded her for 5 years.

Her exclusion ends October 2026. Maria has been working in retail for three years and wants to return to healthcare billing. She found this buried in the OIG website: "In order to participate in Medicare, Medicaid and all other Federal health care programs once the term of exclusion ends, the individual or entity must apply for reinstatement and receive written notice from OIG that reinstatement has been granted."

Maria needs to apply 90 days before October 2026, meaning she needs to submit in July 2026.

(a) There is no form. She has to write a letter. OIG's reinstatement page says to submit "a written request" to OIG at P.O. Box 23871 or by email. No template. No checklist. No guidance on what the letter must include.

(b) OIG will then send her Statement and Authorization forms. These must be completed, notarized, and returned. She doesn't know what these look like.

(c) Her reinstatement application needs a "Corrective Action Plan" and "evidence of remediation." OIG's list: completed sanctions, license reinstatement documentation, education/training records, compliance monitoring reports, letters of professional reference. Maria doesn't know what a corrective action plan for a civil settlement looks like.

(d) If OIG denies her application, she must wait a full year to reapply. The stakes of getting the first application wrong are significant.

(e) Every attorney she called quoted $3,500–$6,000 to handle her reinstatement. For a billing specialist earning $42k in retail, that's 3+ months' net pay.

Who receives this

Healthcare workers excluded from Medicare/Medicaid who are approaching the end of their exclusion period and need to apply for reinstatement. Primary: lower-income excluded individuals (medical billing specialists, medical assistants, home health aides, certified nursing assistants) excluded for billing/fraud-adjacent conduct who cannot afford attorney representation. Secondary: nurses and pharmacists with permissive exclusions (license revocation) at mid-income levels. Not primary: physicians ($200k+ income to attorney-mandatory) or cases with long exclusion periods (10+ years, OIG waiver required).

Why the agency will not advise you

OIG Exclusions staff process reinstatement applications but cannot advise excluded individuals on how to strengthen their petition. The entire LEIE software industry (Verisys, ProviderTrust, AccountableHQ, Verify Comply, Assured Health, Compliancy Group) is built for employers to screen their workforce, not to help excluded individuals apply for reinstatement. The educational content gap is total, guides exist but no product assembles the documentation.

Key facts, with sources

• OIG excludes approximately 3,000 individuals and entities per year from participation in Medicare, Medicaid, and all federal healthcare programs. Exclusion is added to the LEIE (List of Excluded Individuals/Entities). Minimum exclusion period for mandatory exclusions (conviction for program-related crimes, patient abuse): 5 years (42 U.S.C. § 1320a-7(c)(3)(B)). Permissive exclusions (license revocation, misdemeanors, default on health education loans) can be shorter. Once the minimum exclusion period ends, reinstatement is NOT automatic, the individual must apply. OIG published reinstatement statistics: roughly 2 reinstatement DENIAL appeals are heard per year, meaning the vast majority of applications are either granted or withdrawn. The excluded population eligible for reinstatement at any given time: roughly 15,000 (3,000 new/year × 5-year average exclusion). The LEIE software market (Verify Comply, Assured Health, Compliancy Group, ProviderTrust, AccountableHQ, Verisys) is entirely focused on helping EMPLOYERS check whether employees or contractors appear on the LEIE, none of these tools serve excluded individuals seeking reinstatement. Educational guides exist (AccountableHQ, ProviderTrust, exclusionscreening.com, National Security Law Firm) but no product builds the documentation package. Source: Reinstatements | Office of Inspector General – HHS · How to Apply for OIG Reinstatement – Exclusion Screening · How to Get Reinstated After HHS OIG Exclusion | National Security Law Firm
• The OIG reinstatement application process requires substantially more than a form submission. Per oig.hhs.gov/exclusions/reinstatement.asp: (1) write a reinstatement request to OIG (P.O. Box 23871, Washington DC 20026 or [email protected]); (2) OIG sends Statement and Authorization forms, the excluded party must complete, have NOTARIZED, and return; (3) OIG reviews 'evidence of remediation': completed sanctions, license reinstatement if applicable, corrective action plan, training records, monitoring reports, letters of professional reference; (4) OIG issues written reinstatement notice or denial, process can take up to 120 days. If denied, the individual may reapply after one year. Attorney market: Chapman Law Group (chapmanlawgroup.com/practice_areas/oig-state-exclusions), The Health Law Firm (thehealthlawfirm.com), OIG Appeal & Reinstatement Lawyers at Callahan Law Firm (lawcallahan.com/practice-areas/oig-appeals-and-reinstatements), Liles Parker PLLC (lilesparker.com/oig-exclusion-law) all offer OIG reinstatement services. Typical attorney cost for reinstatement: $2,500–$8,000 for standard applications; $10,000–$20,000 if denial likely or multi-state Medicaid exclusion reinstatement required. Income range of excluded individuals: physicians ($200k+, attorney-mandatory), pharmacists ($110k), nurses ($60k–80k), medical assistants ($40k), billing staff ($35k–45k), home health aides ($25k–$30k). Lower-income excluded individuals represent the clearest addressable market for a $79–$149 tool. Source: OIG & State Medicare/Medicaid Exclusions | Chapman Law Group · OIG Appeal & Reinstatement | Callahan Law Firm · OIG Exclusion Law | Liles Parker PLLC

When to bring in a professional

Self-serve responses fit routine cases: clear facts, amounts a business can absorb, and a deadline still ahead of you. Bring in a licensed professional when the amount at stake is large relative to their fee, the facts are genuinely disputed, criminal exposure is possible, or the deadline has already passed. A short paid consultation to sanity-check your plan is often worth it even when you handle the filing yourself.

All sources for this guide

1. Reinstatements | Office of Inspector General – HHS
2. How to Apply for OIG Reinstatement – Exclusion Screening
3. How to Get Reinstated After HHS OIG Exclusion | National Security Law Firm
4. OIG & State Medicare/Medicaid Exclusions | Chapman Law Group
5. OIG Appeal & Reinstatement | Callahan Law Firm
6. OIG Exclusion Law | Liles Parker PLLC