Ohio FACIS® background checks: Levels 1M & 3 explained
A Ohio-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from Ohio 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 Ohio?
FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds Ohio sources: the Ohio Medicaid Sanctioned or Excluded Provider List, the Ohio Medicaid Fraud Control Unit, and disciplinary records from the Ohio medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.
Every Ohio 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 Ohio and which level fits your workforce.
What is a FACIS® background check in Ohio?
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 Ohio candidate, a Level 3 FACIS® search reaches into the Ohio Medicaid Sanctioned or Excluded Provider List, the Ohio Medicaid Fraud Control Unit, and the disciplinary records of every Ohio healthcare licensing board.
Ohio sources included in FACIS® Level 3
- Ohio Medicaid Sanctioned or Excluded Provider List
- Ohio Medicaid Fraud Control Unit enforcement actions
- Ohio Board of Medicine disciplinary actions
- Ohio Board of Nursing disciplinary actions
- Ohio Board of Pharmacy disciplinary actions
- Ohio dental, behavioral health, and allied-health board actions
- Ohio Attorney General healthcare-fraud actions
- Ohio contractor disqualification and debarment lists
Ohio hiring rules that shape a healthcare screening program
FACIS® answers the exclusion question, but a Ohio healthcare hire also runs into state-specific reporting and inquiry rules. Ohio applies FCRA. Sealed and expunged records under ORC §2953.32 must be suppressed.
Criminal-history inquiry timing. State agencies may not inquire about criminal history on initial applications. That matters for clinical hiring in Ohio 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. ORC §3796.28 (medical) and Issue 2 preserve the employer's right to enforce zero-tolerance policies.
Salary history. Major city ordinances apply; no statewide rule.
Practical note for Ohio providers. K-12 reprint required every five years under ORC §3319.39.
Primary Ohio citations: ORC §9.73 · ORC §2953.32 · Issue 2 (2023)
Full detail lives in the Ohio 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 Ohio 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 Ohio employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Ohio Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| OH licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Ohio AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Ohio employers need Level 3?
If any of the following describe your Ohio organization, Level 3 is the right search. Level 1M is not enough to see OH board sanctions or Ohio Medicaid exclusions:
- Ohio hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Ohio
- Home health, hospice, and DME suppliers billing Ohio Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Ohio
- Any employer with clinical staff holding a OH license alongside licenses in other states
How often should Ohio providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Ohio Medicaid enrollment agreements generally impose the same monthly cadence against the Ohio 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 Ohio employers
SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a Ohio 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 Ohio employers
A single-name FACIS® Level 3 search on a Ohio 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 OH board or Ohio 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 Ohio hire.
Building a complete Ohio healthcare hiring package
FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Ohio clinical hiring package typically pairs FACIS® Level 3 with:
- Primary-source license verification against the Ohio Board of Medicine, Ohio Board of Nursing, and Ohio Board of Pharmacy
- County criminal history for every Ohio county lived or worked in during the FCRA lookback window
- National sex offender registry and Ohio-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Ohio employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Ohio finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Ohio background check laws for the state-level rules that shape package design, and the package builder to assemble a Ohio healthcare package end-to-end.
Frequently asked questions about FACIS® in Ohio
What is the penalty if a Ohio 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 Ohio can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Ohio healthcare hires?
For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For Ohio 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 Ohio?
No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a OH license is currently active and in good standing. SafestHires runs primary-source license verification against each Ohio board alongside FACIS® on every clinical hire.
