Montana FACIS® background checks: Levels 1M & 3 explained
A Montana-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from Montana 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 Montana?
FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds Montana sources: the Montana Medicaid Sanctioned or Excluded Provider List, the Montana Medicaid Fraud Control Unit, and disciplinary records from the Montana medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.
Every Montana 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 Montana and which level fits your workforce.
What is a FACIS® background check in Montana?
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 Montana candidate, a Level 3 FACIS® search reaches into the Montana Medicaid Sanctioned or Excluded Provider List, the Montana Medicaid Fraud Control Unit, and the disciplinary records of every Montana healthcare licensing board.
Montana sources included in FACIS® Level 3
- Montana Medicaid Sanctioned or Excluded Provider List
- Montana Medicaid Fraud Control Unit enforcement actions
- Montana Board of Medicine disciplinary actions
- Montana Board of Nursing disciplinary actions
- Montana Board of Pharmacy disciplinary actions
- Montana dental, behavioral health, and allied-health board actions
- Montana Attorney General healthcare-fraud actions
- Montana contractor disqualification and debarment lists
Montana hiring rules that shape a healthcare screening program
FACIS® answers the exclusion question, but a Montana healthcare hire also runs into state-specific reporting and inquiry rules. Montana applies FCRA; the state has a wrongful-discharge statute that affects discipline based on prior records.
Criminal-history inquiry timing. State-agency hiring removed the conviction question; no statewide private rule. That matters for clinical hiring in Montana 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. I-190 and HB 701 protect off-duty use for non-safety-sensitive roles. Employers retain rights for federal-mandate positions.
Salary history. No statewide salary-history ban.
Practical note for Montana providers. Wrongful-discharge protections under MCA §39-2-901 apply to discipline based on stale records.
Primary Montana citations: MCA §39-2-313 (off-duty conduct) · HB 701 (2021)
Full detail lives in the Montana 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 Montana 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 Montana employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Montana Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| MT licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Montana AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Montana employers need Level 3?
If any of the following describe your Montana organization, Level 3 is the right search. Level 1M is not enough to see MT board sanctions or Montana Medicaid exclusions:
- Montana hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Montana
- Home health, hospice, and DME suppliers billing Montana Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Montana
- Any employer with clinical staff holding a MT license alongside licenses in other states
How often should Montana providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Montana Medicaid enrollment agreements generally impose the same monthly cadence against the Montana 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 Montana employers
SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a Montana 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 Montana employers
A single-name FACIS® Level 3 search on a Montana 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 MT board or Montana 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 Montana hire.
Building a complete Montana healthcare hiring package
FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Montana clinical hiring package typically pairs FACIS® Level 3 with:
- Primary-source license verification against the Montana Board of Medicine, Montana Board of Nursing, and Montana Board of Pharmacy
- County criminal history for every Montana county lived or worked in during the FCRA lookback window
- National sex offender registry and Montana-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Montana employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Montana finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Montana background check laws for the state-level rules that shape package design, and the package builder to assemble a Montana healthcare package end-to-end.
Frequently asked questions about FACIS® in Montana
What is the penalty if a Montana 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 Montana can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Montana healthcare hires?
For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For Montana 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 Montana?
No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a MT license is currently active and in good standing. SafestHires runs primary-source license verification against each Montana board alongside FACIS® on every clinical hire.