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District of Columbia FACIS® background checks: Levels 1M & 3 explained

A District of Columbia-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from District of Columbia boards and Medicaid enforcement, and which level fits which employer.

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Short answer

What is the difference between FACIS® Level 1M and Level 3 in District of Columbia?

FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds District of Columbia sources: the DC Medicaid Excluded / Terminated Providers List, the DC Medicaid Fraud Control Unit (Office of the Attorney General), and disciplinary records from the District of Columbia medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.

Every District of Columbia organization that bills a federally funded healthcare program — Medicare, Medicaid, TRICARE, or a state Medicaid managed-care plan — is required to verify that its employees, contractors, and vendors are not excluded from participation. FACIS® is the standard tool for that verification. This guide covers what a FACIS® search returns in District of Columbia and which level fits your workforce.

What is a FACIS® background check in District of Columbia?

FACIS® (Fraud and Abuse Control Information System) is a healthcare-specific sanction database that aggregates federal exclusion and debarment records with state licensing, Medicaid, and Attorney General enforcement data. Run against a District of Columbia candidate, a Level 3 FACIS® search reaches into the DC Medicaid Excluded / Terminated Providers List, the DC Medicaid Fraud Control Unit (Office of the Attorney General), and the disciplinary records of every District of Columbia healthcare licensing board.

District of Columbia sources included in FACIS® Level 3

  • DC Medicaid Excluded / Terminated Providers List
  • DC Medicaid Fraud Control Unit (Office of the Attorney General) enforcement actions
  • District of Columbia Board of Medicine disciplinary actions
  • District of Columbia Board of Nursing disciplinary actions
  • District of Columbia Board of Pharmacy disciplinary actions
  • District of Columbia dental, behavioral health, and allied-health board actions
  • District of Columbia Attorney General healthcare-fraud actions
  • District of Columbia contractor disqualification and debarment lists

District of Columbia hiring rules that shape a healthcare screening program

FACIS® answers the exclusion question, but a District of Columbia healthcare hire also runs into state-specific reporting and inquiry rules. The Fair Criminal Record Screening Amendment caps conviction reporting at ten years from completion of sentence and prohibits any consideration of arrests not leading to conviction. Effective January 1, 2026, the Second Chance Amendment Act (D.C. Law 24-284) phases in automatic sealing and expungement of decriminalized offenses — including pre-2015 marijuana convictions — and other eligible older records, and expressly bars criminal-history providers from reporting anything sealed, expunged, or set aside.

Criminal-history inquiry timing. Employers with 11+ employees may not inquire about a candidate's criminal history until after a conditional offer. Since January 1, 2026, employers may not access or act on any record sealed or expunged under the Second Chance Amendment Act, and the Office of Human Rights may adjudicate complaints and impose penalties. That matters for clinical hiring in District of Columbia because a FACIS® hit and a county criminal hit often arrive together, and the order in which you may act on them is set by state law, not by the report.

Drug and cannabis testing. The Cannabis Employment Protections Amendment Act protects most employees from adverse action for off-duty cannabis use, with carve-outs for safety-sensitive and federally regulated positions.

Salary history. The Wage Transparency Amendment Act of 2023 requires pay range and benefits in job postings and prohibits wage-history inquiries.

Practical note for District of Columbia providers. Strongest single-jurisdiction stack in the country — sequence pre-adverse and adverse-action timing carefully, and re-verify any DC record pulled before January 1, 2026 against the Second Chance sealing rollout.

Primary District of Columbia citations: D.C. Code §2-1402.66 · D.C. Law 24-284 (Second Chance Amendment Act, eff. 1/1/2026) · Wage Transparency Amendment Act 2023 · Cannabis Employment Protections Amendment Act 2022

Full detail lives in the District of Columbia background check guide.

Federal sources included in every FACIS® search

Both Level 1M and Level 3 include the federal exclusion sources that satisfy OIG and CMS baseline requirements for District of Columbia providers:

  • OIG List of Excluded Individuals and Entities (LEIE)
  • System for Award Management (SAM), including SDN
  • OFAC Specially Designated Nationals list
  • FDA Debarment List
  • DEA administrative actions
  • GSA excluded parties
  • TRICARE excluded providers
  • U.S. Department of Justice, Treasury, and State healthcare-fraud actions

FACIS® Level 1M vs. Level 3 for District of Columbia employers

Federal exclusion listsLevel 1M ✓   Level 3 ✓
District of Columbia Medicaid exclusionsLevel 1M ✗   Level 3 ✓
DC licensing board disciplinary actionsLevel 1M ✗   Level 3 ✓
District of Columbia AG healthcare-fraud actionsLevel 1M ✗   Level 3 ✓

Which District of Columbia employers need Level 3?

If any of the following describe your District of Columbia organization, Level 3 is the right search. Level 1M is not enough to see DC board sanctions or District of Columbia Medicaid exclusions:

  • District of Columbia hospitals, health systems, and physician groups
  • Skilled nursing, assisted-living, and long-term-care operators in District of Columbia
  • Home health, hospice, and DME suppliers billing District of Columbia Medicaid
  • Behavioral health, telehealth, and substance-use providers licensed in District of Columbia
  • Any employer with clinical staff holding a DC license alongside licenses in other states

How often should District of Columbia providers re-screen?

The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. District of Columbia Medicaid enrollment agreements generally impose the same monthly cadence against the DC Medicaid Excluded / Terminated Providers List. A pre-hire FACIS® check is the starting point; continuous monthly monitoring is what catches sanctions that land after the hire date.

How SafestHires runs FACIS® for District of Columbia employers

SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a District of Columbia healthcare hiring package alongside primary-source license verification, sex-offender registry checks, and county criminal history. Ongoing monthly monitoring is available for the entire workforce from the same dashboard.

FACIS® turnaround time for District of Columbia employers

A single-name FACIS® Level 3 search on a District of Columbia candidate typically returns in minutes because most sources are queried via live API. Manual review kicks in only when the search returns a potential match that needs DC board or District of Columbia Medicaid-exclusion identifier confirmation before it can be reported. See the SafestHires turnaround guide for a full breakdown of what drives timing across all searches in a District of Columbia hire.

Building a complete District of Columbia healthcare hiring package

FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete District of Columbia clinical hiring package typically pairs FACIS® Level 3 with:

  • Primary-source license verification against the District of Columbia Board of Medicine, District of Columbia Board of Nursing, and District of Columbia Board of Pharmacy
  • County criminal history for every District of Columbia county lived or worked in during the FCRA lookback window
  • National sex offender registry and District of Columbia-specific abuse/neglect registry lookups
  • Employment and education verification, including internship and residency dates
  • Drug screening under District of Columbia employer policy — 5- or 10-panel lab-based
  • Financial Risk Search for District of Columbia finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)

See District of Columbia background check laws for the state-level rules that shape package design, and the package builder to assemble a District of Columbia healthcare package end-to-end.

Frequently asked questions about FACIS® in District of Columbia

What is the penalty if a District of Columbia employer bills for services from an excluded provider?

Under 42 U.S.C. §1320a-7a, civil monetary penalties can reach up to $21,000 per item or service claimed, plus treble damages, plus repayment of every dollar that touched the excluded person's work. State Medicaid Fraud Control Units in District of Columbia can pursue additional penalties under state false-claims statutes.

Is a Financial Risk Search recommended for District of Columbia healthcare hires?

For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For District of Columbia healthcare finance, revenue-cycle, and executive roles with fiduciary responsibility, the SafestHires Financial Risk Search — bankruptcies, civil judgments, and tax liens from public records — is a common add-on to surface public financial-risk indicators before hire.

Does FACIS® replace primary-source license verification in District of Columbia?

No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a DC license is currently active and in good standing. SafestHires runs primary-source license verification against each District of Columbia board alongside FACIS® on every clinical hire.

Other state FACIS® guides

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