Background Checks – Compliance ReminderThe U.S. Department of Health and Human Services Office of Inspector General (OIG) recently released an audit report which reviewed compliance with background checks and abuse-registry requirements in skilled nursing facilities. The audit identified instances where staff began working before these required screenings were completed.
This serves as an important reminder for providers: federal and state regulations require background checks and registry screenings to be completed and documented before an individual begins working in a long-term care facility.
Regulatory Reminders
F-Tag F606 – Not Employ/Engage Staff with Adverse Actions
The regulation applies to all staff including employees, contractors, consultants, volunteers, students, and medical directors.
F606 requires facilities to not hire or engage individuals with:
- Court findings of abuse, neglect, exploitation, misappropriation, or mistreatment.
- State nurse aide registry listings with findings of abuse, neglect, exploitation, misappropriation, or mistreatment
- Active disciplinary actions against professional licenses for abuse, neglect, exploitation, misappropriation, or mistreatment
Fair Credit Reporting Act Section 606 – If an investigative background report is ordered, the facility must provide the applicant with a stand-alone written disclosure within three days of requesting the report, along with a summary of their rights under the FCRA.
Take Action Now
- Review compliance policies – Confirm that background checks and registry queries are completed before the first day of work.
- Update onboarding workflows – Build pre-start verification steps into your hiring process.
- Educate hiring teams – Train managers and HR staff on the scope of F-Tag F606, registry checklist requirements, and FCRA timing/disclosure rules.
- Include all worker types – Screen not only direct care staff, but also volunteers, contractors, consultants, students, and medical directors.
- Document verification efforts – Keep clear records of checks performed for every staff member.
- Audit regularly – Conduct routine internal reviews to identify and correct any gaps in compliance.