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Every Healthcare Screening Program Must Include a FACIS Search

Healthcare providers must meet several state and federal compliance mandates in order to reduce fraud and protect their patients. This means they must carefully screen new hires and monitor existing employees. Checking a candidate’s criminal history, verifying past employment, viewing education credentials and validating licenses are all advisable. While healthcare organizations may differ on what specific searches to cover, every healthcare screening program must include a FACIS search.

SafestHires recommends the following Best Practices for a healthcare screening program.

  1. Protect Your Organization with a Background Investigation
    Every healthcare employee can add a dimension of risk to the workplace. This is compunded by a need to hire quickly, often while working with limited resources. Performing background investigations on candidates, employees, volunteers, and contractors can be an effective way to discover and address potential risks.

  2. Follow Legally Required Procedures
    Government regulations generally require that you obtain written permission before conducting a background check. This requires a disclosure and authorization form that should be separate from other hiring documents.

  3. Validate Identity and Verify Address History
    Knowing a candidate’s current and past addresses is critical for a thorough background check. Discovering the candidate’s address history will help identify where to search for criminal records as well as helping to understand any inconsistencies with information provided by the candidate. The person’s Social Security Number is used to validadte their identity based on public record information. This information will reveal when the SSN was issued, if it matches the person’s name listed in public record sources, and any possible aliases associated with the candidate’s social security number which can help discover criminal records associated with these names.

  4. Discover Job Related Criminal History
    Criminal searches conducted at the county level can offer a more accurate picture because there is no national databse containing all criminal records. A national criminal database search can be useful, however, to reveal if a candidate has committed any crimes outside their counties of residence, like places they have visited or worked.
  5. Confirm the Candidate’s Work History
    Determining if a candidate has been truthful about employment dates, compensation, and job titles with descriptions by contacting past employers can help ensure the candidate is a good fit for the position. Some employers use an automated system to perform verifications, which provide limited information.

  6. Check Education Credentials
    There have been several well-publicized incidents where emplyees embellished their education. If they are willing to do this just to get a job, what else would they do or say – and at whose expense – to get a raise or promotion? Making sure a candidate has been truthful about their education is a critical accountability tool.

  7. Perform a FACIS Search (Healthcare Sanctions)
    A FACIS search includes information on disciplinary actions ranging from exclusions and debarments to letters of reprimand and probation. A basic FACIS search covers the federal government’s minimum requirements as outlined in the OIG’s Compliance Program Guidance and includes: OIG, GSA, DEA, FDA, PHS, ORI, TRICARE and OFAC-SDN data (federal only) and Medicare Opt-Out. A comprehensive FACIS search includes the minimum federal requirements plus more than 800 reporting sources in all 50 states.

  8. Require a Drug Test
    Based on the type of position, you may want to require a drug test, especially if any impairment from drug use could place patients at risk for harm. Drug testing provides an additional layer of protection and peace of mind.

  9. Correctly Implement Adverse Action
    The FCRA requires that an employer follow specific steps before taking adverse action against a candidate or employee. The term “adverse action” could mean denial of employment or any other decision that negatively impacts the candidate’s emplyment situation. The Federal Trade Commison describes an employer’s legally required responsibilities here.

  10. Monitor & Update Your Program
    Because a healthcare organization can still be fined or penalized if an employee gets added to a sanctions list after they’ve been hired, monthly monitoring with a FACIS search is highly advisable.

The last and probably the most important “Best Practice” is to have your screening program approved by experienced legal counsel. This will help give you a defensible position if any potential violations are raised.

If you’d like assistance setting up a screening program for your healthcare organization, please follow the link below to schedule a call with a SafestHires screening consultant.

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