What is the difference between FACIS Level 1M and FACIS Level 3?

FACIS Level 1M is the baseline that meets OIG and CMS minimum requirements, covering the OIG LEIE, SAM, and core federal sanction sources. FACIS Level 3 adds 3,500+ primary sources including all 56 U.S. jurisdictions' state licensing boards, Medicaid exclusion lists, and additional federal databases.

Who is required to run FACIS background checks?

Any organization that receives federal or state healthcare funding — including hospitals, health systems, physician groups, home health agencies, long-term care facilities, and their vendors — must screen employees and contractors against the OIG LEIE and SAM at minimum before hire and monthly thereafter.

FACIS Background Checks: Levels 1M and 3 Explained (2026 Guide)

Q: What is a FACIS background check?

FACIS (Fraud and Abuse Control Information System) is a healthcare-focused sanction database used to screen employees, contractors, and vendors against federal and state exclusion, debarment, and disciplinary lists.

If you employ anyone who touches a Medicare, Medicaid, TRICARE, or other federally funded patient — clinicians, billing staff, contracted transporters, IT vendors, cleaning crews — you are on the hook to verify that person has not been excluded from participating in federal healthcare programs. A single missed hit can trigger civil monetary penalties of up to $21,000 per item claimed, plus repayment of every dollar that person’s services touched. FACIS is the industry’s standard way to run that verification.

What is a FACIS background check?

FACIS (Fraud and Abuse Control Information System) is a proprietary healthcare-sanction database used by background screeners to check a person or entity against exclusion, debarment, and disciplinary lists maintained by federal agencies and by every U.S. state and territory. The search is name-, DOB-, and identifier-matched and returns any adverse action attached to that identity across the covered sources.

FACIS is sold in tiered levels. The two levels healthcare employers actually use are Level 1M (the OIG-and-CMS baseline) and Level 3 (the all-source, all-jurisdiction search).

FACIS Level 1M background check

FACIS Level 1M is the minimum search that satisfies the Office of Inspector General’s Compliance Program Guidance and CMS conditions of participation. It screens against federal exclusion and debarment sources, including:

OIG List of Excluded Individuals and Entities (LEIE)
System for Award Management (SAM), including SDN
OFAC Specially Designated Nationals list
FDA Debarment List
OPM Debarred Providers

Level 1M is a reasonable floor for organizations that only need to demonstrate OIG/CMS compliance and that operate in a single, low-complexity setting. It is not sufficient if you employ licensed professionals whose disciplinary history lives with a state board — which is nearly every healthcare employer.

FACIS Level 3 background check

FACIS Level 3 is the comprehensive search. It includes everything in Level 1M and adds thousands of state-level primary sources — roughly 3,500 in total — covering all 56 U.S. jurisdictions (50 states, DC, and 5 territories) across every provider type.

State sources typically covered by Level 3 include:

State Medicaid exclusion and sanctioned-provider lists
State contractor disqualification and debarment lists
State licensing board disciplinary actions — medicine, nursing, pharmacy, dental, mental health, allied health
State Attorney General healthcare-fraud actions
HEAT (Healthcare Fraud Prevention and Enforcement Action Team) Task Force actions
Medicare and Medicaid opt-out lists

Federal sources covered by Level 3 include:

OIG LEIE
SAM (including SDN)
FDA Debarment
DEA administrative actions
GSA excluded parties
TRICARE excluded providers
FBI most-wanted and healthcare-fraud actions
U.S. Department of Justice
U.S. Department of the Treasury (OFAC)
U.S. Department of State

Which FACIS level does your organization need?

The short answer: if you employ or contract with anyone holding a state professional license — RN, LPN, MD, DO, PharmD, LCSW, RT, PT, OT, dental hygienist — you need Level 3. Level 1M cannot see a state nursing board suspension or a pharmacy board revocation, and those are exactly the actions that indicate elevated patient-safety risk.

Level 1M is the right choice for:

Vendors and contractors with no licensed staff working on-premises
Single-jurisdiction employers with no clinical roles
Supplementary monthly monitoring where Level 3 was run at hire

Level 3 is the right choice for:

Hospitals, health systems, and multi-site provider groups
Long-term care, skilled nursing, and assisted-living operators
Home health, hospice, and DME suppliers
Behavioral health, telehealth, and Medicaid-managed-care organizations
Any employer with clinical staff licensed in more than one state

How often should FACIS be run?

The OIG Special Advisory Bulletin recommends monthly re-screening against exclusion lists. The LEIE is updated monthly; SAM and most state boards are updated on rolling cycles. A single pre-hire FACIS search is a starting point, not a program. Ongoing monitoring is how you catch the nurse who was sanctioned six months into their employment.

How SafestHires runs FACIS

SafestHires offers both FACIS Level 1M and FACIS Level 3 as standalone searches or as part of a healthcare hiring package that also includes primary-source license verification, sex-offender registry checks, and county criminal history. Reports are returned in the same platform as the rest of the background check, so there is one file per hire and one dashboard for ongoing monitoring.

FACIS background check guides by state

FACIS Level 3 covers every U.S. jurisdiction, but each state contributes different exclusion lists, boards, and Medicaid fraud enforcement patterns. Use the directory below for a state-specific breakdown of what Level 3 pulls in for your workforce.