Health care providers need to meet several federal and state compliance requirements in order to reduce fraud and protect their patients.
This includes verifying licenses and conducting a comprehensive sanctions investigation on all employees participating in the administration of federal health care programs. HireRight engages its clients in an ongoing dialogue regarding their background screening needs.
These conversations produced the following 10 common background screening best practices for health care providers:
- Protect Your Organization – Make a Commitment to Background Verification
Each and every health care employee can add a level of risk to the workplace. The health care industry also has high standards regarding candidate quality, and the need to hire quickly, while often working with limited talent acquisition resources. Performing background screening on candidates, employees, volunteers, and contractors can be an effective way to discover potential risks or issues that could affect your business.
- Obtain Written Consent – Use Appropriate Forms Correctly
Government regulations generally require that you must have your candidate’s or employee’s written permission to perform a background check. This requires a disclosure and consent form that should be separate from any employment application form.
- Trace Address History and Validate SSN – Note Discrepancies and Past Addresses
A list of the candidate’s current and past addresses is the foundation for a thorough background check. Locating past counties that the person is associated with is useful for both deciding where to look for criminal records as well as to look for time gaps and location mismatches compared to the information provided by the candidate. A person’s Social Security Number (SSN) is typically issued sometime between birth and a first job. Through a SSN Validation you can note major discrepancies in identity such as if the SSN that your candidate provided you was issued prior to their date of birth. It is also important to consider any aliases or “aka names” associated with the candidate’s social security number in order to help ensure that you find all possible criminal records associated with names the candidate may have used in the past.
- Conduct a Comprehensive Criminal Check – Expose Potential Criminal History
Criminal searches conducted at the individual county level can offer a more complete view of criminal history since there is no national centralized entity controlling all criminal records. For even more confidence, consider using national criminal database checks in conjunction with local county criminal searches to locate additional records from places an candidate or employee may have visited and places of residence or employment that were not disclosed.
- Confirm Work History – Verify Past Employment
Attempting to verify employment dates, actual compensation, and job titles with descriptions by directly contacting past employers can help validate the candidate’s fit for your position. Some past employers may decline to provide any information, so it may help to ask the candidate to provide a written request and release to previous employers authorizing their disclosure of information when this happens.
- Validate Education and Licenses – Confirm Credentials and Status
When degrees or education are important for a position, validating a candidate’s claims by directly contacting the listed educational institutions or their agents will provide the most reliable information. There have been several well-publicized incidents of employees overstating their education in recent years.
- Utilize Health Care Exclusion Lists – Eliminate Candidates Who Do Not Meet Basic Criteria
Identify individuals who have been sanctioned or are excluded from participation in federal health care programs, such as Medicare or Medicaid, to avoid penalties, fines, and other problems. Search the List of Excluded Individuals/Entities (LEIE) of the U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG) and the General Services Administration (GSA).
- Expand Core Screening – Learn More About Candidates
Based on the type of position you are hiring, you may consider additional checks to learn more about your candidate. Consider standardizing your screens based on the position.
- Comply with Laws and Regulations – Follow the Rules for Adverse Actions
As an employer, you may have certain additional legal obligations when you intend to take any “adverse action” based in whole or in part on the information resulting from a background check. The term adverse action in the employment screening context may mean any denial of employment or any other decision for employment purposes that adversely affects any current or prospective employee. The FTC has issued some guidance to help employers better understand the FCRA.
- Stay Ahead of the Curve – Reassess Your Program Annually
Requirements for participation in federal health care programs do not end after an employee has been hired. Fines and penalties could be imposed on an organization even if an employee was added to a sanctions list after pre-employment screening was conducted.
Reviewing this blog posting can help your organization benchmark its performance against these best practices for healthcare organizations. If your organization has any questions or needs help filling the gaps in its screening program, you should contact HireRight.
Free Report: HireRight Health Care Spotlight
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HireRight Health Care Spotlight