Pennsylvania FACIS background checks: Levels 1M & 3 explained
A Pennsylvania-specific breakdown of the FACIS healthcare exclusion search: what Level 1M covers, what Level 3 adds from Pennsylvania boards and Medicaid enforcement, and which level fits which employer.
Every Pennsylvania 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 Pennsylvania and which level fits your workforce.
What is a FACIS background check in Pennsylvania?
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 Pennsylvania candidate, a Level 3 FACIS search reaches into the Pennsylvania Medicaid Sanctioned or Excluded Provider List, the Pennsylvania Medicaid Fraud Control Unit, and the disciplinary records of every Pennsylvania healthcare licensing board.
Pennsylvania sources included in FACIS Level 3
- Pennsylvania Medicaid Sanctioned or Excluded Provider List
- Pennsylvania Medicaid Fraud Control Unit enforcement actions
- Pennsylvania Board of Medicine disciplinary actions
- Pennsylvania Board of Nursing disciplinary actions
- Pennsylvania Board of Pharmacy disciplinary actions
- Pennsylvania dental, behavioral health, and allied-health board actions
- Pennsylvania Attorney General healthcare-fraud actions
- Pennsylvania contractor disqualification and debarment lists
Pennsylvania hiring rules that shape a healthcare screening program
FACIS answers the exclusion question, but a Pennsylvania healthcare hire also runs into state-specific reporting and inquiry rules. Pennsylvania follows FCRA. Clean Slate sealing (2018) must be suppressed.
Criminal-history inquiry timing. Governor's directive covers state agencies; Philadelphia and Pittsburgh apply private-employer rules. That matters for clinical hiring in Pennsylvania 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. 35 P.S. §10231.2103 prohibits discrimination against medical-cannabis patients absent on-the-job impairment.
Salary history. Applies to state agencies and Philadelphia private employers; no statewide private rule.
Practical note for Pennsylvania providers. Act 153 reprint required every five years for K-12 and child-contact roles.
Primary Pennsylvania citations: 35 P.S. §10231.2103 · 23 Pa.C.S. §6344 (K-12) · Exec. Order 2018-18-03
Full detail lives in the Pennsylvania 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 Pennsylvania 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 Pennsylvania employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Pennsylvania Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| PA licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Pennsylvania AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Pennsylvania employers need Level 3?
If any of the following describe your Pennsylvania organization, Level 3 is the right search. Level 1M is not enough to see PA board sanctions or Pennsylvania Medicaid exclusions:
- Pennsylvania hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Pennsylvania
- Home health, hospice, and DME suppliers billing Pennsylvania Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Pennsylvania
- Any employer with clinical staff holding a PA license alongside licenses in other states
How often should Pennsylvania providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Pennsylvania Medicaid enrollment agreements generally impose the same monthly cadence against the Pennsylvania 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 Pennsylvania employers
SafestHires offers FACIS Level 1M and FACIS Level 3 as standalone searches or bundled into a Pennsylvania 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 Pennsylvania employers
A single-name FACIS Level 3 search on a Pennsylvania 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 PA board or Pennsylvania 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 Pennsylvania hire.
Building a complete Pennsylvania healthcare hiring package
FACIS is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Pennsylvania clinical hiring package typically pairs FACIS Level 3 with:
- Primary-source license verification against the Pennsylvania Board of Medicine, Pennsylvania Board of Nursing, and Pennsylvania Board of Pharmacy
- County criminal history for every Pennsylvania county lived or worked in during the FCRA lookback window
- National sex offender registry and Pennsylvania-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Pennsylvania employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Pennsylvania finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Pennsylvania background check laws for the state-level rules that shape package design, and the package builder to assemble a Pennsylvania healthcare package end-to-end.
Frequently asked questions about FACIS in Pennsylvania
What is the penalty if a Pennsylvania 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 Pennsylvania can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Pennsylvania healthcare hires?
For clinical roles, FACIS plus primary-source license verification and county criminal history is the compliance-driven baseline. For Pennsylvania 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 Pennsylvania?
No. FACIS surfaces disciplinary and sanction history, but it does not confirm that a PA license is currently active and in good standing. SafestHires runs primary-source license verification against each Pennsylvania board alongside FACIS on every clinical hire.