Virginia FACIS® background checks: Levels 1M & 3 explained
A Virginia-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from Virginia 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 Virginia?
FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds Virginia sources: the Virginia Medicaid Sanctioned or Excluded Provider List, the Virginia Medicaid Fraud Control Unit, and disciplinary records from the Virginia medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.
Every Virginia 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 Virginia and which level fits your workforce.
What is a FACIS® background check in Virginia?
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 Virginia candidate, a Level 3 FACIS® search reaches into the Virginia Medicaid Sanctioned or Excluded Provider List, the Virginia Medicaid Fraud Control Unit, and the disciplinary records of every Virginia healthcare licensing board.
Virginia sources included in FACIS® Level 3
- Virginia Medicaid Sanctioned or Excluded Provider List
- Virginia Medicaid Fraud Control Unit enforcement actions
- Virginia Board of Medicine disciplinary actions
- Virginia Board of Nursing disciplinary actions
- Virginia Board of Pharmacy disciplinary actions
- Virginia dental, behavioral health, and allied-health board actions
- Virginia Attorney General healthcare-fraud actions
- Virginia contractor disqualification and debarment lists
Virginia hiring rules that shape a healthcare screening program
FACIS® answers the exclusion question, but a Virginia healthcare hire also runs into state-specific reporting and inquiry rules. Virginia applies FCRA. Expunged records under Va. Code §19.2-392.2 must be suppressed. Effective July 1, 2026, Virginia's Clean Slate chapter (Va. Code §§19.2-392.6:1 through 19.2-392.17) adds automatic and petition-based sealing for many misdemeanors and certain lower-level felonies, and §19.2-392.16 places direct limits on what a business screening service may disseminate.
Criminal-history inquiry timing. Governor Northam's 2020 executive order removed the conviction question from state-agency initial applications. Effective July 1, 2026, Va. Code §19.2-392.15 prohibits employers not otherwise subject to a federal inquiry mandate from requiring an applicant to disclose a sealed arrest, charge, or conviction — in an application, an interview, or otherwise — and the applicant may lawfully answer as if the record does not exist. Unauthorized disclosure of a sealed record is a Class 1 misdemeanor under §19.2-392.14. That matters for clinical hiring in Virginia 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. Va. Code §40.1-27.4 protects medical-cannabis patients with a valid certification; recreational use does not carry off-duty protection.
Salary history. No statewide salary-history ban, but the Virginia Values Act creates enhanced pay-equity remedies.
Practical note for Virginia providers. Clean Slate is live as of July 1, 2026 — sealed Virginia records must be treated as non-reportable and cannot be asked about. VSP fingerprint pathway under VA Code §22.1-296.2 still applies for K-12 hires.
Primary Virginia citations: Va. Code §19.2-392.2 · Va. Code §19.2-392.13 (eff. 7/1/2026) · Va. Code §19.2-392.15 (eff. 7/1/2026) · Va. Code §19.2-392.16 (eff. 7/1/2026) · Va. Code §40.1-27.4 · Exec. Order 41
Full detail lives in the Virginia 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 Virginia 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 Virginia employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Virginia Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| VA licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Virginia AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Virginia employers need Level 3?
If any of the following describe your Virginia organization, Level 3 is the right search. Level 1M is not enough to see VA board sanctions or Virginia Medicaid exclusions:
- Virginia hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Virginia
- Home health, hospice, and DME suppliers billing Virginia Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Virginia
- Any employer with clinical staff holding a VA license alongside licenses in other states
How often should Virginia providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Virginia Medicaid enrollment agreements generally impose the same monthly cadence against the Virginia 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 Virginia employers
SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a Virginia 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 Virginia employers
A single-name FACIS® Level 3 search on a Virginia 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 VA board or Virginia 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 Virginia hire.
Building a complete Virginia healthcare hiring package
FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Virginia clinical hiring package typically pairs FACIS® Level 3 with:
- Primary-source license verification against the Virginia Board of Medicine, Virginia Board of Nursing, and Virginia Board of Pharmacy
- County criminal history for every Virginia county lived or worked in during the FCRA lookback window
- National sex offender registry and Virginia-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Virginia employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Virginia finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Virginia background check laws for the state-level rules that shape package design, and the package builder to assemble a Virginia healthcare package end-to-end.
Frequently asked questions about FACIS® in Virginia
What is the penalty if a Virginia 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 Virginia can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Virginia healthcare hires?
For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For Virginia 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 Virginia?
No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a VA license is currently active and in good standing. SafestHires runs primary-source license verification against each Virginia board alongside FACIS® on every clinical hire.