Vermont FACIS® background checks: Levels 1M & 3 explained
A Vermont-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from Vermont 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 Vermont?
FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds Vermont sources: the Vermont Medicaid Sanctioned or Excluded Provider List, the Vermont Medicaid Fraud Control Unit, and disciplinary records from the Vermont medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.
Every Vermont 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 Vermont and which level fits your workforce.
What is a FACIS® background check in Vermont?
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 Vermont candidate, a Level 3 FACIS® search reaches into the Vermont Medicaid Sanctioned or Excluded Provider List, the Vermont Medicaid Fraud Control Unit, and the disciplinary records of every Vermont healthcare licensing board.
Vermont sources included in FACIS® Level 3
- Vermont Medicaid Sanctioned or Excluded Provider List
- Vermont Medicaid Fraud Control Unit enforcement actions
- Vermont Board of Medicine disciplinary actions
- Vermont Board of Nursing disciplinary actions
- Vermont Board of Pharmacy disciplinary actions
- Vermont dental, behavioral health, and allied-health board actions
- Vermont Attorney General healthcare-fraud actions
- Vermont contractor disqualification and debarment lists
Vermont hiring rules that shape a healthcare screening program
FACIS® answers the exclusion question, but a Vermont healthcare hire also runs into state-specific reporting and inquiry rules. Vermont applies FCRA. Expunged records under 13 V.S.A. §7601 must be suppressed.
Criminal-history inquiry timing. Employers may not inquire about criminal history on the initial application except where federal law mandates inquiry. That matters for clinical hiring in Vermont 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. Act 86 (2018) legalized adult use; 21 V.S.A. §513 preserves drug-free workplace rights.
Salary history. Employers may not seek wage-history information.
Practical note for Vermont providers. Federal-law exception is narrow — DOT and Department of Energy-regulated only.
Primary Vermont citations: 21 V.S.A. §495j · 21 V.S.A. §495m · 21 V.S.A. §513
Full detail lives in the Vermont 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 Vermont 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 Vermont employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Vermont Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| VT licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Vermont AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Vermont employers need Level 3?
If any of the following describe your Vermont organization, Level 3 is the right search. Level 1M is not enough to see VT board sanctions or Vermont Medicaid exclusions:
- Vermont hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Vermont
- Home health, hospice, and DME suppliers billing Vermont Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Vermont
- Any employer with clinical staff holding a VT license alongside licenses in other states
How often should Vermont providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Vermont Medicaid enrollment agreements generally impose the same monthly cadence against the Vermont 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 Vermont employers
SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a Vermont 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 Vermont employers
A single-name FACIS® Level 3 search on a Vermont 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 VT board or Vermont 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 Vermont hire.
Building a complete Vermont healthcare hiring package
FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Vermont clinical hiring package typically pairs FACIS® Level 3 with:
- Primary-source license verification against the Vermont Board of Medicine, Vermont Board of Nursing, and Vermont Board of Pharmacy
- County criminal history for every Vermont county lived or worked in during the FCRA lookback window
- National sex offender registry and Vermont-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Vermont employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Vermont finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Vermont background check laws for the state-level rules that shape package design, and the package builder to assemble a Vermont healthcare package end-to-end.
Frequently asked questions about FACIS® in Vermont
What is the penalty if a Vermont 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 Vermont can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Vermont healthcare hires?
For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For Vermont 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 Vermont?
No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a VT license is currently active and in good standing. SafestHires runs primary-source license verification against each Vermont board alongside FACIS® on every clinical hire.