MUSTER.
Muster Roll

Exclusion screening, handled for you.

Every month, we check the people and companies you employ or pay against the federal and state exclusion lists. We sort out the false matches, tell you about any real ones the same day, and hand you the documentation.

What Muster Roll does

Federal health care programs do not pay for work performed by an excluded person or company, and an organization that employs or contracts with one can face repayment and penalties. Checking your roster against the exclusion lists every month is how you catch it. We do that checking for you.

1. We keep the list of who gets checked

Employees, contractors, agency staff, providers, vendors and their owners, and the board members and volunteers you choose to include. New hires and new vendors are added as they come on.

2. We run the check every month

Every name, against the OIG exclusion list (LEIE), SAM.gov, the CMS Preclusion List, and the Medicaid exclusion list for each state you choose.

3. We resolve the matches

Most hits are false alarms from a shared name. We look into each one and tell you whether it is the same person. A real match is reported to you in writing the same day.

4. We give you the proof

A monthly record of who was checked, against which lists, and how each match was resolved, ready to hand to an auditor or surveyor.

Why it is called Muster Roll. A muster roll is the official list of who is in the unit. Anyone can run a name against the LEIE. The hard part is proving that nobody was left off the list that was run, and that is the part we take on.

The OIG publishes the settlements

When an organization settles with the OIG over employing or contracting with an excluded person, the settlement is posted on the OIG's public enforcement page, with the organization's name and the amount.

The cases read alike. An excluded person was on the payroll or the vendor list, nobody caught it, and the organization agreed to pay to resolve it. Published settlements for employing a single excluded individual have run from about $21,000 to more than $500,000.

Hospitals, senior living operators, dialysis centers, and community providers all appear there. A monthly check, with a record that it was done, is what keeps an organization off that page.

See the OIG's enforcement actions

Where the finding comes from

Screening rarely fails because a list went unchecked. It fails because the covered population was never fully assembled — a staffing agency's roster, a vendor's managing employees, a volunteer nobody thought to include. The gap is invisible from inside the screening tool, and it is the first thing a surveyor reaches for.

The roster is built from four independent sources

Onboarding constructs the covered-population roster and reconciles these against each other. The discrepancies between them are the deliverable.

Payroll register

Every employee, without regard to role or duties. The baseline the other three are measured against.

Accounts payable vendor master

Every entity paid. Owners and managing employees fall within the screened population and are rarely revisited after contracting.

Contract register

Contractors, locums, agency staff, and subrecipients. Frequently held in a spreadsheet, sometimes in no system at all.

Governance and volunteer records

Board members, volunteers, and students, per the scope the client elects. They appear in no payroll run and are the most commonly omitted group.

The reconciliation is the product. Ongoing completeness is maintained through monthly roster deltas and confirmed by a quarterly reconciliation against payroll and the vendor master. An organization that has never reconciled these four typically finds people it was not screening — a finding better received from us than from a surveyor.

Start here: the Roster Baseline Assessment

A one-time, fixed-fee engagement answering a single question — who are we not screening? It stands alone and obligates you to nothing afterward.

Fixed fee by roster size: under 100 people $2,500 · 100 to 500 $4,500 · 500 to 1,500 $7,500 · over 1,500 by quote.

Request a baseline assessment

We reconcile the four sources against your current screening roster and hand you the difference, name by name.

Most organizations expect a handful of gaps. What surfaces is usually a category — an entire class of people nobody had assigned to anyone. Contracted therapists. A staffing agency's roster. The owners of a vendor that has billed you for three years.

Scoped deliberately so it can be done once, understood in a single meeting, and acted on without a standing engagement.

What you receive
  • Reconciled roster across payroll, vendor master, contracts, and governance records
  • Named list of individuals and entities absent from current screening
  • Gap categories, with the system-of-record failure behind each
  • Covered-population definition you can adopt as policy
  • Ownership map: who maintains which source, going forward
  • Findings memo suitable for your compliance committee or board

The monthly cycle

You transmit roster changes. We run the sources, resolve every result, and deliver the evidence. You act on anything confirmed.

Roster

Roster maintenance

Hires, terminations, new contractors, and new vendors reconciled into the covered population each cycle, with additions flagged for pre-engagement screening timing.

Screening

All elected sources

The OIG List of Excluded Individuals and Entities, SAM exclusion records, the CMS Preclusion List, and the Medicaid exclusion and ineligible-provider list for every state you elect. Additional lists on request.

On demand

Pre-engagement screening

Handled as a committed-turnaround transaction, not folded into the monthly rhythm. The failure mode here is someone starting work before the check clears, and a monthly cycle cannot prevent that.

Resolution

Every result resolved

No match, confirmed match, or unresolved — each with the identifiers compared and the basis recorded. A confirmed match is escalated in writing to your designated contact the same day, because exposure accrues for every item or service furnished while the person remains in a billable role. Nothing is silently closed.

Evidence

Monthly evidence package

Dated results, resolution records, and an exception report — delivered to you each cycle. You hold a copy of every package, so we are never the system of record for your own compliance evidence.

Quarterly

Reconciliation and annual summary

Quarterly reconciliation of the roster against payroll and the vendor master, and an annual summary written for a survey binder or a board report rather than for a systems administrator.

Tiers

Priced on a one-time onboarding fee, a monthly base, and a per-covered-individual rate banded by roster size. Quoted to your roster after the baseline.

Request Muster Roll pricing

Basic

The monthly cycle and reporting. Roster maintenance stays with you; quarterly reconciliation is available separately.

Managed

Adds roster maintenance, quarterly reconciliation, and the annual summary. The tier most organizations need, because the roster is the part that drifts.

Managed + AuditLimited

Adds an independent annual test of the screening record. Available only where Muster does not also hold your designated officer role — see below.

Boundaries we hold

Stated here rather than buried in an engagement letter, because they are the reason to trust the work.

At most two of three roles

For any one client, Muster will hold no more than two of: author of the compliance policy, designated compliance or privacy officer, operator of the screening service. Holding all three leaves nobody to check the work. The election is made at engagement and recorded in writing.

You act; we inform and document

Out of scope by design: employment decisions, credentialing and privileging, payer enrollment, overpayment quantification, self-disclosure, and legal advice on the effect of any particular exclusion. We document what we compared and what we concluded.

Workforce data, never patient data

Rosters are workforce records. We do not accept patient data into this workflow for any reason, and we do not request full Social Security numbers as a matter of course — only the identifier needed to resolve a specific match, and not retained past resolution.

What we warrant. That we ran the elected sources on schedule and resolved every result to a documented disposition. We do not warrant the completeness or currency of third-party government databases, and nothing here is legal advice.

Who this is for

Organizations where screening is technically happening and nobody is confident the list is complete.

Community health centers
Behavioral health and SUD providers
Residential and community-based providers
Grant subrecipients and pass-through entities
Organizations with heavy contracted or agency staffing
Compliance officers covering more than one entity

Find out who's missing.

Twenty minutes. Tell us how your roster is assembled today and we'll tell you where the gap is most likely sitting.

Book a 20-minute call