Wisconsin FACIS® background checks: Levels 1M & 3 explained
A Wisconsin-specific breakdown of the FACIS® healthcare exclusion search: what Level 1M covers, what Level 3 adds from Wisconsin boards and Medicaid enforcement, and which level fits which employer.
FACIS®, powered by Verisys, is a registered trademark owned by the Verisys Corporation.
Short answer
What is the difference between FACIS® Level 1M and Level 3 in Wisconsin?
FACIS® Level 1M covers federal exclusion sources — OIG-LEIE, SAM.gov, and OFAC. FACIS® Level 3 adds Wisconsin sources: the Wisconsin Medicaid Sanctioned or Excluded Provider List, the Wisconsin Medicaid Fraud Control Unit, and disciplinary records from the Wisconsin medical, nursing, and pharmacy boards. Level 3 is the standard for direct-patient-care and licensed roles.
Every Wisconsin 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 Wisconsin and which level fits your workforce.
What is a FACIS® background check in Wisconsin?
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 Wisconsin candidate, a Level 3 FACIS® search reaches into the Wisconsin Medicaid Sanctioned or Excluded Provider List, the Wisconsin Medicaid Fraud Control Unit, and the disciplinary records of every Wisconsin healthcare licensing board.
Wisconsin sources included in FACIS® Level 3
- Wisconsin Medicaid Sanctioned or Excluded Provider List
- Wisconsin Medicaid Fraud Control Unit enforcement actions
- Wisconsin Board of Medicine disciplinary actions
- Wisconsin Board of Nursing disciplinary actions
- Wisconsin Board of Pharmacy disciplinary actions
- Wisconsin dental, behavioral health, and allied-health board actions
- Wisconsin Attorney General healthcare-fraud actions
- Wisconsin contractor disqualification and debarment lists
Wisconsin hiring rules that shape a healthcare screening program
FACIS® answers the exclusion question, but a Wisconsin healthcare hire also runs into state-specific reporting and inquiry rules. Wisconsin applies FCRA. Pardons and expungements under Wis. Stat. §973.015 must be suppressed.
Criminal-history inquiry timing. Governor Evers' 2019 executive order removed the conviction question from state-agency initial applications. That matters for clinical hiring in Wisconsin 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. Wisconsin permits limited CBD use; no recreational or broad medical legalization.
Salary history. No statewide salary-history ban.
Practical note for Wisconsin providers. Wis. Stat. §111.335 prohibits discrimination based on convictions unsubstantially related to the position.
Primary Wisconsin citations: Wis. Stat. §111.335 (conviction-record discrimination) · Wis. Stat. §973.015
Full detail lives in the Wisconsin 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 Wisconsin 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 Wisconsin employers
| Federal exclusion lists | Level 1M ✓ Level 3 ✓ |
| Wisconsin Medicaid exclusions | Level 1M ✗ Level 3 ✓ |
| WI licensing board disciplinary actions | Level 1M ✗ Level 3 ✓ |
| Wisconsin AG healthcare-fraud actions | Level 1M ✗ Level 3 ✓ |
Which Wisconsin employers need Level 3?
If any of the following describe your Wisconsin organization, Level 3 is the right search. Level 1M is not enough to see WI board sanctions or Wisconsin Medicaid exclusions:
- Wisconsin hospitals, health systems, and physician groups
- Skilled nursing, assisted-living, and long-term-care operators in Wisconsin
- Home health, hospice, and DME suppliers billing Wisconsin Medicaid
- Behavioral health, telehealth, and substance-use providers licensed in Wisconsin
- Any employer with clinical staff holding a WI license alongside licenses in other states
How often should Wisconsin providers re-screen?
The OIG Special Advisory Bulletin recommends monthly re-screening against the LEIE. Wisconsin Medicaid enrollment agreements generally impose the same monthly cadence against the Wisconsin 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 Wisconsin employers
SafestHires offers FACIS® Level 1M and FACIS® Level 3 as standalone searches or bundled into a Wisconsin 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 Wisconsin employers
A single-name FACIS® Level 3 search on a Wisconsin 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 WI board or Wisconsin 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 Wisconsin hire.
Building a complete Wisconsin healthcare hiring package
FACIS® is the sanction-and-exclusion layer of a healthcare hire, but it is only one component. A complete Wisconsin clinical hiring package typically pairs FACIS® Level 3 with:
- Primary-source license verification against the Wisconsin Board of Medicine, Wisconsin Board of Nursing, and Wisconsin Board of Pharmacy
- County criminal history for every Wisconsin county lived or worked in during the FCRA lookback window
- National sex offender registry and Wisconsin-specific abuse/neglect registry lookups
- Employment and education verification, including internship and residency dates
- Drug screening under Wisconsin employer policy — 5- or 10-panel lab-based
- Financial Risk Search for Wisconsin finance, revenue-cycle, and executive roles with fiduciary duties (bankruptcies, judgments, liens from public records)
See Wisconsin background check laws for the state-level rules that shape package design, and the package builder to assemble a Wisconsin healthcare package end-to-end.
Frequently asked questions about FACIS® in Wisconsin
What is the penalty if a Wisconsin 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 Wisconsin can pursue additional penalties under state false-claims statutes.
Is a Financial Risk Search recommended for Wisconsin healthcare hires?
For clinical roles, FACIS® plus primary-source license verification and county criminal history is the compliance-driven baseline. For Wisconsin 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 Wisconsin?
No. FACIS® surfaces disciplinary and sanction history, but it does not confirm that a WI license is currently active and in good standing. SafestHires runs primary-source license verification against each Wisconsin board alongside FACIS® on every clinical hire.