Michigan FACIS background checks: Levels 1M & 3 explained
A Michigan-specific breakdown of the FACIS healthcare exclusion search: what Level 1M covers, what Level 3 adds from Michigan boards and Medicaid enforcement, and which level fits which employer.
Every Michigan 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 Michigan and which level fits your workforce.
What is a FACIS background check in Michigan?
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 Michigan candidate, a Level 3 FACIS search reaches into the Michigan Medicaid Sanctioned or Excluded Provider List, the Michigan Medicaid Fraud Control Unit, and the disciplinary records of every Michigan healthcare licensing board.
Michigan sources included in FACIS Level 3
- Michigan Medicaid Sanctioned or Excluded Provider List
- Michigan Medicaid Fraud Control Unit enforcement actions
- Michigan Board of Medicine disciplinary actions
- Michigan Board of Nursing disciplinary actions
- Michigan Board of Pharmacy disciplinary actions
- Michigan dental, behavioral health, and allied-health board actions
- Michigan Attorney General healthcare-fraud actions
- Michigan contractor disqualification and debarment lists
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 Michigan 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 Michigan employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Michigan Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| MI licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Michigan AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Michigan employers need Level 3?
If any of the following describe your Michigan organization, Level 3 is the right search. Level 1M is not enough to see MI board sanctions or Michigan Medicaid exclusions:
- Michigan hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Michigan
- Home health, hospice, and DME suppliers billing Michigan Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Michigan
- Any employer with clinical staff holding a MI license alongside licenses in other states
How often should Michigan providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Michigan Medicaid enrollment agreements generally impose the same monthly cadence against the Michigan Medicaid Sanctioned or Excluded Provider 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 Michigan employers
SafestHires offers FACIS Level 1M and FACIS Level 3 as standalone searches or bundled into a Michigan 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 Michigan employers
A single-name FACIS Level 3 search on a Michigan 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 MI board or Michigan 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 Michigan hire.
Building a complete Michigan healthcare hiring package
FACIS is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Michigan clinical hiring package typically pairs FACIS Level 3 with:
- Primary-source license verification against the Michigan Board of Medicine, Michigan Board of Nursing, and Michigan Board of Pharmacy
- County criminal history for every Michigan county lived or worked in during the FCRA lookback window
- National sex offender registry and Michigan-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Michigan employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Michigan finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Michigan background check laws for the state-level rules that shape package design, and the package builder to assemble a Michigan healthcare package end-to-end.
Frequently asked questions about FACIS in Michigan
What is the penalty if a Michigan 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 Michigan can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Michigan healthcare hires?
For clinical roles, FACIS plus primary-source license verification and county criminal history is the compliance-driven baseline. For Michigan 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 Michigan?
No. FACIS surfaces disciplinary and sanction history, but it does not confirm that a MI license is currently active and in good standing. SafestHires runs primary-source license verification against each Michigan board alongside FACIS on every clinical hire.