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. While healthcare organizations may differ on what specific searches to cover, every healthcare screening program must include a FACIS search.

SafestHires Recommended Best Practices

1. Protect Your Organization with a Background Investigation

Every healthcare employee can add a dimension of risk to the workplace — compounded by a need to hire quickly 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 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. The Social Security Number is used to validate identity based on public record information — revealing when the SSN was issued, whether it matches the person's name, and any possible aliases.

4. Discover Job-Related Criminal History

County-level criminal searches offer a more accurate picture because there is no national database containing all criminal records. A national criminal database search can also be useful to reveal crimes committed outside the candidate's counties of residence.

5. Confirm Work History

Determining if a candidate has been truthful about employment dates, compensation, and job titles by contacting past employers helps ensure the candidate is a good fit for the position.

6. Check Education Credentials

There have been several well-publicized incidents where employees embellished their education. 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, OFAC-SDN data (federal only), and Medicare Opt-Out. A comprehensive FACIS search adds 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. Drug testing provides an additional layer of protection.

9. Correctly Implement Adverse Action

The FCRA requires that an employer follow specific steps before taking adverse action against a candidate or employee. "Adverse action" could mean denial of employment or any other decision that negatively impacts the candidate's employment situation.

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 Most Important Best Practice

Have your screening program approved by experienced legal counsel. This will help give you a defensible position if any potential violations are raised.