January 2026 OIG Investigations Relating to Unlicensed Individual

Already in 2026, the Office of Inspector General has cited several Nursing Facilities for hiring excluded individuals.  

On January 9, 2026, OIG alleged that Avantara North violated the Civil Monetary Penalty Law by submitting claims for services provided by an excluded individual.  The nursing home agreed to pay $20,000 to resolve the allegation.  

Several other non-nursing-facility-providers settled cases in the same month for the same "Excluded Individual" violation, signaling a broad enforcement sweep:

• Castle Biosciences (Jan 9, 2026): Agreed to pay $112,000 for allegedly employing an excluded individual.

• Brickyard Healthcare - Willow Springs Care Center (Jan 26, 2026): While the technical charge was "unlicensed individual," this nursing home paid $99,000 for billing services provided by a person not legally authorized to provide them, which follows the same investigative logic as exclusion cases.

• Lake Minnetonka Shores (Jan 20, 2026): A senior living/nursing facility that paid $113,000 for billing services provided by an unlicensed staff member.

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OIG regulations and Medicare/Medicaid rules require that nursing homes periodically review their staff and vendors to ensure they are not excluded individuals or entities.  Facilities cannot bill Medicare or Medicaid for any services that excluded persons/vendors provide. This essentially creates an employment embargo on those individuals and vendors.

Searching the name of every employee and vendor against the OIG Exclusion List (LEIE) is a monumental task, especially when it has to be done monthly in some states, such as required by Medicaid contracts in the Commonwealth of Virginia.  

Perla’s compliance platform streamlines the OIG verification process of staff and vendors by automating the process, saving hundreds of hours of time and potential penalties each year. OIG verification does not have to be complicated or break the bank. Learn how you can save with Perla by Booking a Demo.