Considerations for Creating an Ongoing Healthcare Background Check Policy

Considerations for Creating an Ongoing Healthcare Background Check Policy
Senior Director of Marketing

While hospitals and other healthcare organizations generally aren’t required to run time-of-hire or ongoing background checks, they often do as part of their voluntary due diligence procedures and to mitigate their liability risk. Some states do require background checks for candidates for certain healthcare positions, but organizations typically run them on all staff members.

According to a research report from the Society for Human Resource Management, 24 percent of healthcare organizations, social assistance organizations, nursing homes and EAP providers perform ongoing background checks. And organizations across all industries that perform ongoing background checks do so at a variety of points, including:

  • When an employee has a change in status (full-time to part-time or a lateral move), 42 percent.
  • When there’s a promotion or investigation, 32 percent.
  • On an annual basis, 18 percent.
  • Once after a year of employment, 6 percent.

What Kind of Background Check Policy Should You Have?

If your organization is interested in performing ongoing background checks, one of the most important things it can do is have a policy that follows applicable federal and state laws, attorney Margaret J. Lowery says. Laws can vary widely by states. For example, in Illinois, the policy would need to comply with the Illinois Health Care Worker Background Check Act

Additionally, applicants in any state must be checked against sex offender registries, state and U.S. Department of Health and Human Services Office of the Inspector General exclusion lists, and the U.S. Department of the Treasury Office of Foreign Asset Control list, Lowery says. All employees who work in healthcare organizations that receive federal funds must be continuously checked against the state and federal exclusion lists

What Should It Check?

Although healthcare organizations’ preferences vary, some of the components can include:

  • Criminal history (county, state, etc.).
  • Sanction and exclusion screening.
  • Searches of sex offender registries.
  • Verification of licensure.
  • Verification of previous and current employment.
  • Verification of education.
  • Credit checks, when applicable.

A strong policy also would require employees to notify the employer if their status or licensure changes, Lowery says. Include information about any regulations the organization must follow, such as physician recredentialing, which includes requirements such as querying the National Practitioner DataBank, Lowery says.

Stay Compliant

Keep in mind that when you put a policy together, it needs to be compliant with current laws. For example, under the Fair Credit Reporting Act, employers must notify employees about the background check and let them know if something disqualifies them from the job. Not complying with the FCRA can create liability for employers.


Once you’ve put together a policy, following it and documenting it are key, Lowery says. “Maintain evidence that the policy was followed by way of background checks in the employee’s personnel file and that the policy is enforced consistently,” Lowery says. “The biggest mistake HR makes is not following their own policy and also not rechecking current employees’ background, especially for exclusion or licensure issues.” Not performing checks or enforcing the policy inconsistently can bring accusations of unfairness or discrimination.

Putting together a strong ongoing background check policy can protect your organization and help ensure your employees are the best for your needs.

Are you currently updating your healthcare organization’s background screening practices? Contact us today to learn how PreCheck can help you streamline your ongoing background screening, exclusion screening, and license monitoring programs.

PreCheck Background Screening Resource Kit