{
  "study": {
    "slug": "leie-exclusion-trends-2026",
    "title": "Provider exclusions aren't rising — but they cluster around distressed operators",
    "standfirst": "New additions to the OIG exclusion list are flat to declining — down 2.4% year-over-year through April 2026, and down 18.7% across full-year 2024 to 2025. The count is not the story. What concentrates is the composition: new exclusions cluster in facilities already showing the balance-sheet markers of financial distress.",
    "desk": "financial-distress",
    "article_type": "Original Research",
    "published": "2026-05-05",
    "issue": 46,
    "doi": "10.5072/fonteum/leie-2026-q1",
    "url": "https://fonteum.com/research/leie-exclusion-trends-2026",
    "methodology_version": "distress-proxy/v1"
  },
  "data_as_of": "2026-05-01",
  "datasets": [
    {
      "slug": "oig-leie",
      "name": "OIG LEIE",
      "publisher": "HHS OIG — List of Excluded Individuals/Entities",
      "upstream_url": null
    },
    {
      "slug": "cms-pecos",
      "name": "CMS PECOS",
      "publisher": "CMS — Provider Enrollment, Chain & Ownership System",
      "upstream_url": null
    }
  ],
  "key_findings": [
    {
      "number": "2.4%",
      "finding": "decline in new OIG LEIE exclusion additions year-over-year through April 2026",
      "dataset": "oig-leie"
    },
    {
      "number": "18.7%",
      "finding": "decline in new exclusions across full-year 2024 (3,134) to 2025 (2,549)",
      "dataset": "oig-leie"
    },
    {
      "number": "2.4×",
      "finding": "more likely — institutional exclusions attached to already-distressed operators vs financially stable ones",
      "dataset": "oig-leie"
    },
    {
      "number": "83,001",
      "finding": "total exclusion records in the OIG LEIE snapshot this analysis is frozen against (cms-leie-2026-05-08)",
      "dataset": "oig-leie"
    }
  ],
  "faqs": [
    {
      "q": "Are Medicare provider exclusions rising?",
      "a": "No. New additions to the OIG List of Excluded Individuals and Entities (LEIE) are flat to declining — down 2.4% year-over-year through April 2026, and down 18.7% across full-year 2024 (3,134 additions) to 2025 (2,549). Exclusion volume fluctuates with enforcement capacity and a reporting lag; the raw count is not climbing."
    },
    {
      "q": "What is the OIG LEIE?",
      "a": "The List of Excluded Individuals and Entities is the HHS Office of Inspector General's federal registry of providers barred from participating in Medicare, Medicaid, and other federal health programs. It is a punitive, trailing record — an exclusion lands long after the conduct that prompted it — which is what makes it useful as a cohort signal rather than a real-time one."
    },
    {
      "q": "What does it mean that exclusions cluster around distressed operators?",
      "a": "Among matched institutional exclusions, an exclusion is about 2.4 times more likely to attach to an operator the cost reports had already flagged as financially distressed than to a stable one. The distress proxy is built from HCRIS — negative operating margin across two consecutive cost-report periods and a current ratio below one. Distress and misconduct share upstream causes, so the two datasets together flag a short watch-list neither produces alone."
    },
    {
      "q": "Is the distress proxy an audited financial judgment?",
      "a": "No. \"Distressed\" here is a coarse, public-data proxy built entirely from HCRIS cost reports, designed to be reproducible rather than authoritative. It is not an audit, a credit rating, or a solvency opinion, and many thin-margin operators never cross into misconduct."
    },
    {
      "q": "Can I reproduce these figures?",
      "a": "Yes. Every figure aggregates the oig-leie/2026-05 snapshot (frozen 2026-05-01), joined to PECOS enrollment by NPI and to the HCRIS distress proxy. The year-over-year counts, the year-to-date comparison, and the 2.4x relative-risk ratio each regenerate from the SQL published in the reproducibility block below."
    }
  ],
  "citation": {
    "apa": "Fonteum Research. (2026, May 05). Provider exclusions aren't rising — but they cluster around distressed operators. Fonteum Research, Issue 46. https://doi.org/10.5072/fonteum/leie-2026-q1",
    "url": "https://fonteum.com/research/leie-exclusion-trends-2026"
  },
  "reproducible_sql": "-- Provider exclusions are flat to declining — but they cluster around\n-- distressed operators. (Corrigendum 2026-06-01: the original \"rising\" framing\n-- was not reproducible from the committed snapshot; additions are down 2.4%\n-- Jan–Apr 2026 vs 2025 and down 18.7% full-year 2024→2025. The clustering\n-- finding is unchanged.)\n-- Snapshot: oig-leie/2026-05 (oig_leie_snapshot, snapshot_date = 2026-05-01).\n-- Joins new exclusions to PECOS enrollment and to an HCRIS-derived\n-- financial-distress proxy. Each query is annotated with its expected result.\n\n-- ── (1) New LEIE additions by calendar year — full-year 2024 -> 2025 ──────────\nselect extract(year from excl_date)::int as yr, count(*) as additions\nfrom oig_leie_snapshot\nwhere dataset_id = 'oig-leie'\n  and snapshot_date = date '2026-05-01'\n  and excl_date >= date '2024-01-01'\n  and excl_date <  date '2026-01-01'\ngroup by 1\norder by 1;\n--  2024  3,134\n--  2025  2,549      (18.7% decline: (3134 - 2549) / 3134 = 0.187)\n\n-- ── (1b) Year-to-date additions, Jan–Apr 2026 vs Jan–Apr 2025 ────────────────\n-- New additions are essentially flat: down 2.4% year-over-year through April.\nselect\n  round(100.0 * (\n    count(*) filter (where excl_date >= date '2026-01-01' and excl_date < date '2026-05-01')\n    - count(*) filter (where excl_date >= date '2025-01-01' and excl_date < date '2025-05-01')\n  ) / nullif(count(*) filter (where excl_date >= date '2025-01-01'\n                              and excl_date < date '2025-05-01'), 0), 1) as ytd_yoy_pct\nfrom oig_leie_snapshot\nwhere dataset_id = 'oig-leie'\n  and snapshot_date = date '2026-05-01';\n-- ytd_yoy_pct = -2.4   (Jan–Apr 2026 additions 2.4% below Jan–Apr 2025)\n\n-- ── (2) The structure — new exclusions cluster around distressed operators ────\nwith new_exclusions as (\n  select npi, exclusion_type, excl_date\n  from oig_leie_snapshot\n  where dataset_id = 'oig-leie'\n    and snapshot_date = date '2026-05-01'\n    and excl_date >= date '2026-01-01'\n),\ndistress as (\n  -- Coarse public-data proxy: negative operating margin across two\n  -- consecutive cost-report periods AND a current ratio below one.\n  select npi,\n         (neg_margin_2_periods and current_ratio < 1.0) as distressed\n  from hcris_facility_summary\n),\njoined as (\n  select e.npi,\n         e.exclusion_type,\n         coalesce(d.distressed, false) as distressed,\n         (e.exclusion_type = 'entity') as institutional\n  from new_exclusions e\n  left join distress d using (npi)\n)\nselect\n  institutional,\n  distressed,\n  count(*) as exclusions\nfrom joined\ngroup by 1, 2\norder by 1 desc, 2 desc;\n-- The matched-institutional rows split ~2.4 : 1 distressed : stable (query 2b).\n\n-- ── (2b) The relative-risk headline: 2.4x ───────────────────────────────────\n-- Among matched institutional (entity) exclusions, how many sit at an operator\n-- the cost reports already flagged as distressed, relative to a stable one.\nwith new_exclusions as (\n  select npi, exclusion_type\n  from oig_leie_snapshot\n  where dataset_id = 'oig-leie'\n    and snapshot_date = date '2026-05-01'\n    and excl_date >= date '2026-01-01'\n),\ndistress as (\n  select npi, (neg_margin_2_periods and current_ratio < 1.0) as distressed\n  from hcris_facility_summary\n),\njoined as (\n  select coalesce(d.distressed, false) as distressed,\n         (e.exclusion_type = 'entity')  as institutional\n  from new_exclusions e\n  left join distress d using (npi)\n)\nselect\n  round(\n    count(*) filter (where institutional and distressed)::numeric\n    / nullif(count(*) filter (where institutional and not distressed), 0), 1\n  ) as distressed_to_stable_ratio\nfrom joined;\n-- distressed_to_stable_ratio = 2.4   (institutional exclusions are 2.4x more\n--   likely to attach to an already-distressed operator than to a stable one)",
  "license": "U.S. Government Works (federal sources; 17 U.S.C. §105)",
  "generated_by": "Fonteum — https://fonteum.com",
  "notes": "Aggregate, source-traced figures frozen to the snapshot above. Reproduce by running reproducible_sql against the cited federal dataset; no per-entity records are included."
}