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ABC Hospital is in the process of revising their processes for conducting exclusion checks on employees and contractors through the use of a third-party vendor.

ABC Hospital is in the process of revising their processes for conducting exclusion checks on employees and contractors through the use of a third-party vendor. In preparing for the launch of the new process, this vendor has asked for a database listing all employees and contractors. According to the OIG guidance, does ABC hospital need to include contractors that do not provide items or services reimbursable by a Federal health care program, such as "Joe's Restaurant" that catered the holiday party?

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