5 Healthcare Employment Screening Best Practices to Mitigate Risk
As we observe Healthcare Risk Management Week at PreCheck, I thought I would share five healthcare background screening tips to help your organization drive safe and trusted healthcare. As a healthcare background screening firm, protecting patient care as at the heart of our mission and the following list is by no means an exhaustive one. There are certainly more ways that you can mitigate risk through employment screening practices, but the following five best practices are a great way to start.
Establish a Comprehensive Ongoing Exclusion Screening Program
Having an effective exclusion screening program is not only important for protecting patients from being treated from excluded individuals, but also to safeguard your healthcare organization from incurring civil monetary penalties (CMP’s). A comprehensive exclusion screening program would follow the Office of Inspector General’s (OIG’s) latest guidance, issued in 2013, which establishes checking the OIG List of Excluded Individuals and Entities (LEIE) on a monthly basis as the current standard in the industry. A monthly exclusion screening frequency minimizes the level of risk for your organization and is in line with the OIG’s latest guidance.
While the OIG LEIE is the backbone of any exclusion screening program, screening only this exclusion list is not enough. With the Affordable Care Act, an individual that is excluded in one state is considered excluded in all. Therefore, it’s important that your exclusion screening policy also includes checking all the available published State Medicaid Exclusion Lists.
Implement a Random Drug Testing Program
An April 2014 USA Today report shared that more than 100,000 doctors, nurses, medical technicians and healthcare aides are abusing or dependent on prescription drugs in a given year, putting patients at risk. It’s no secret that there is a substance abuse problem among healthcare employees, given the industry’s ease of access to controlled substances.
Last year, Inspector General Daniel R. Levinson and Erika T. Broadhurst from the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) addressed the issue of random drug testing in a March 2014 New York Times Op-Ed article. “We believe hospitals should be required to perform random drug tests on all healthcare workers with access to drugs,” states the OIG’s article.
Following the OIG’s recommendation, implementing a random drug testing program at your healthcare organization can help you protect patients and identify healthcare staff that may need help with overcoming a substance addiction.
Remember to Conduct Ongoing Post-Hire Background Checks
While healthcare organizations generally are not required to run ongoing background checks, they often do as part of their voluntary due diligence procedures and to mitigate their liability risk. According to a research report from the Society for Human Resource Management (SHRM), nearly one in four healthcare organizations, social assistance organizations, nursing homes and EAP providers perform ongoing background checks.
It’s important to remember that a background check represents a snapshot in time. What you find on an employee’s background check may be different one or two years from now. Having an ongoing background check policy can help protect your organization in the long-term, allowing you to keep an eye on your employees after the initial time of hire.
Align Your Medical Staff and HR Background Screening Practices
While physicians are not typically employed by hospitals, it’s important the hospitals and medical staff services departments conduct background checks on appointed physicians and allied health staff. If you review the latest stories in the media, unfortunately, you’ll find that there’s no shortage of physicians with criminal behavior.
In a recent interview for the PreCheck Blog, attorney Jesse Adam Markos of Wachler & Associates stated, “Criminal background checks fill in any potential gaps in credentialing search efforts and help to assure that those gaps do not present quality of care or safety concerns for the organization and its patients.”
Not only is it important that you have a background screening program for medical staff and allied health professionals appointed by your organization’s medical staff services office, but you should also ensure that HR is involved in the process. Healthcare HR departments are typically familiar with the background screening process. Especially for organizations that employ physicians, it’s important that HR and medical services professionals communicate to ensure that the background check policies across departments are consistent and aligned.
Always Primary Source—Don’t Rely on the FBI And Other Inaccurate, Database Criminal Searches
While The Joint Commission requires that healthcare organizations conduct primary source license verifications on professional licensed staff, it’s equally important to go to the primary source when it comes to criminal searches. While some state legislation has required the use of the FBI’s fingerprint background check, it’s highly recommended that you consider its weaknesses before utilizing it in your background screening program.
Database criminal searches are only as accurate as they are updated, which means that you are almost always guaranteed to be missing the latest publically available information. While the FBI fingerprint may seem like a highly accurate criminal search, a 2006 U.S. Attorney General’s Report on Criminal History Background Checks states that “final disposition information for approximately 50 percent of its records” is missing.
The FBI fingerprint background check is a highly inaccurate criminal search. Background screening experts agree. “In reality, the FBI database is far from perfect and should never be regarded as the most reliable source for comprehensive and accurate background screening,” said Melissa Sorenson, Executive Director of the National Association of Professional Background Screeners (NAPBS) in a commentary on Roll Call.