Screening Caregivers Who Enter Clients' Homes
A role-based screening approach for nonmedical and licensed home care workers who work alone in clients' homes.
Short answer
How should agencies screen caregivers who work alone in clients' homes?
Start by separating nonmedical home care from licensed clinical care, because state licensing rules and Medicare conditions apply differently. Then screen for the risks of unsupervised in-home work: criminal history, state abuse and neglect registries where your agency has access, federal health care exclusions, driving records for caregivers who transport clients, and credential checks for licensed staff.
Nonmedical versus licensed clinical care
Nonmedical home care (companionship, personal care, homemaking) is regulated by states, and requirements vary widely. Medicare-certified home health agencies must also meet federal conditions of participation, including aide training and competency rules.
Some states run fingerprint-based programs for long-term care workers under the federal national background check program. Check your state health or human services agency for the program that applies to your license type.
Why exclusion checks matter for both
Federal law allows civil money penalties against a provider that employs or contracts with a person excluded from federal health care programs when services are billed to those programs. That makes OIG and SAM exclusion checks relevant for any agency that bills Medicare or Medicaid.
Role matrix for in-home care
| Role | Common checks | Trigger | Required or optional |
|---|---|---|---|
| Companion / homemaker | Criminal history, abuse registry (where accessible), exclusions if billing federal programs | State licensing; federal billing rules | Depends on state and payer |
| Personal care aide | Criminal history, state registry, exclusions | State licensing; federal billing rules | Depends on state and payer |
| Home health aide (Medicare-certified) | State-required checks, exclusions, competency records | 42 CFR 484.80 and state law | Required as specified by those rules |
| Caregiver who drives clients | Motor vehicle record | Employer and insurer policy | Policy choice |
| RN / LPN | License verification, exclusions, criminal history | State nursing board; federal billing rules | License status required to practice |
Frequently asked questions
Can we search any state's abuse registry?
No. Some states limit registry access to licensed agencies or specific employers. SafestHires can run registry searches only where access rules allow.
Does a clean criminal check replace an exclusion check?
No. Exclusions come from federal and state program lists, not court records, and a person can be excluded without a criminal conviction.
How often should we re-screen?
Many agencies re-check exclusion lists monthly because the lists are updated monthly. Other re-screening intervals are state rules or policy choices.
Related tools and guides
Sources
- 42 CFR § 484.80 — home health aide services (Cornell LII)
- 42 U.S.C. § 1320a-7l — national background check program for long-term care (Cornell LII)
- 42 U.S.C. § 1320a-7a — civil monetary penalties, including employing excluded persons (Cornell LII)
- HHS OIG — List of Excluded Individuals/Entities
- SAM.gov — federal exclusion records
- EEOC — Enforcement Guidance on Arrest and Conviction Records (2012)
Published and last reviewed October 5, 2026.