FCRA Compliance: What Employers Need to Know Before Running Background Checks

As an employer relying on a third party to run background checks on job candidates or existing employees, you must follow the federal Fair Credit Reporting Act (FCRA). Your responsibilities are detailed in the document entitled “Notice to Users of Consumer Reports: Obligations of Users under the FCRA.” Below is a breakdown of your essential duties under the Act. If you have any questions, consult qualified counsel.

GSA - EPLS Exclusion Database Changing to SAM

For many years, PreCheck and the National Healthcare Data Bank (NHDB) have utilized the General Services Administration (GSA) Excluded Parties List System (EPLS) on a daily basis to determine whether an individual or entity is excluded. The EPLS is a federal database containing the names of those individuals and entities that have been barred and excluded from doing business with the federal government.

Sanctions vs. Board Actions

In the world of healthcare the terms Sanctions and Board Actions are commonly used but often misunderstood. Sanctions and exclusions are actions taken by state and federal agencies with sanctioning authority against an individual or entity. Usually, the individual is a licensed healthcare professional. A Board Action, however, is an adverse action taken by a state licensing board against a healthcare professional's license.

Implementation of a strong sanction and exclusion screening program is just one of the various tools you rely on to ensure patient safety and program compliance. Further, conducting sanction screening protects your organization from civil monetary penalties. The requirement to check the names of employees, medical providers, and suppliers against the federal OIG and GSA exclusion lists seems pretty straightforward. Yet, you know that just checking the OIG Exclusions List is not enough.

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