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When the U.S. Department of Health and Human Services (HHS)
Office of Inspector General (OIG) audited one of the nation’s largest
not-for-profit senior health care providers a few years ago, its
management team complied with federal auditors. There was
no reason to worry because this senior care organization did
everything in its power to ensure the safety and well-being of its
more than 20,000 workers and 25,000 patients.
The organization was aware of federal regulations that prohibit
hiring sanctioned individuals and had dedicated personnel at each
of its 240 U.S. facilities, checking every job candidate against the OIG
List of Excluded Individuals/Entities (LEIE). It even partnered with a
background screening vendor to run criminal checks on all applicants.
Yet, during a routine federal audit, authorities uncovered one current
employee with outstanding sanctions who was prohibited from working for health care providers that accept federal funds. In the
end, the government fined the senior care organization $500,000 and warned that if the organization did not improve its employment
screening system and auditors found future violations, the fines would increase.
Hidden Risks Inherent in the Screening ProgramIt may seem that the OIG has a straightforward solution for preventing sanctioned individuals from being employed in health care, but
there are a few big challenges to meet its requirements.
1) There may be time gaps between when a person is sanctioned at the state level and when that offense is reported up to the
federal level and published on the OIG LEIE.
2) Individuals can alter their names, change locations and falsify identifying
information, such as Social Security numbers, in order to hide past sanctions.
3) Many large health care organizations employ thousands of workers, which
increases the chance for lapses in screening and mistakes due to human error.
After the audit, it became clear that immediate changes to the organization’s
screening program were necessary. The audit prompted the senior care
organization to partner with Kroll, now a HireRight company, to design and
implement a comprehensive employment screening program. “Other screening
vendors could not match the turnaround time, accuracy, high level of coverage
and value which HireRight offered,” commented the company’s director of risk
management.
One of the Largest Senior Care Organizations Overhauls Its Screening Program
Hire Safe. Hire Smart. HireRight.SM
While five out of 20,000 employees doesn’t sound like a lot, when you think of that
number in terms of a $500,000 penalty per person, you can
quickly see the value in screening and releasing those workers.
“
“
Customer Success Story
Industry: Health CareOrganization: Long Term CareChallenge: Meeting Federal Employment Screening Regulations
- Director of Risk Management
Hire Safe. Hire Smart. HireRight.SM
HireRight uncovered several weaknesses in the provider’s previous employment screening
program. The old employment screening process was too decentralized. Hundreds of employees
at 240 different locations across the country handled sanctions screenings with no central
system to double-check the work for human error. Further, there was no way to discover aliases
or maiden names used by applicants under which they may be sanctioned. Like most large
decentralized health care employers, this senior care organization found that many individuals
responsible for hiring were unaware of regulatory requirements related to employment
screening and the penalties for an oversight. Workers were also unaware of the risk to the
organization’s brand caused by employing sanctioned workers.
Finally, although the organization had sanctions screening and criminal background
checks in place, these checks were only meeting the minimum regulatory obligations. In
order to account for transient workers, name changes, false identifying information and
time gaps between state sanctions and federal reporting, the organization needed to
greatly increase the scope of its screening.
HireRight Builds a More Centralized, Consistent and Efficient Health Care Employment Screening ProgramTo strengthen its program, the organization centralized its employment screening
processes through an automated web-based screening platform integrated with its
applicant tracking system. As recommended by HireRight, the organization changed the
way it screened candidates and employees by layering a complete criminal history check
on top of robust sanctions and exclusions screening.
The organization expanded its criminal records searches beyond the state where the hiring location is based to include every location the
applicant had lived in for the previous seven years. Further, it expanded its sanctions database screening program by comparing the name
used by the applicant on his or her employment application and all other names associated with the applicant’s Social Security number
against the OIG LEIE and U.S. General Services Administration (GSA) Excluded Parties List System (EPLS). The new employment screening
program also runs the job candidate’s name and other identifiers through national databases for positive matches related to criminal
activity or sanctions and exclusions violations. This broader search helps to ensure that red flags in a candidate’s history are uncovered.
For increased efficiency, the employment screening process was
integrated with the organization’s Lawson payroll system. A
human resources staff member at each of the 240 centers enters
a new hire’s basic information into the payroll system. Any
new payroll data is automatically detected and uploaded to the
employment screening solution’s central database several times a
day. The employment screening solution then runs the new hire
data through the series of background and sanction checks—a
process that typically takes one to two days to complete.
The senior care hiring personnel can access a centralized and
simple dashboard where they can monitor the status of their
Health Care Hiring Regulations
Federal guidelines set up by the Office of Inspector General (OIG) prohibit health care organizations from hiring workers with outstanding sanctions and violations. If a health care organization is found to employ even one sanctioned worker, it can be subject to severe fines, be ordered to reimburse the government for services provided by sanctioned workers, be placed under strict oversight by federal auditors, and may lose its ability to receive federal funding through Medicare and Medicaid.
The company’s management team reflects that the new system has given
its current employees and residents even greater peace of mind, reassuring them
that they will be working and living with safe high-caliber individuals.
“
“- Director of Risk Management
Hire Safe. Hire Smart. HireRight.SM
An Altegrity Company
Copyright © 2011 HireRight, Inc. All rights reserved. HireRight is an Altegrity Company. Certain Altegrity companies provide investigative services. State licensing information can be found at www.altegrity.com/compliance.
new hires and see when someone is cleared in real-time. Further, the
organization, with HireRight’s help, educated its hiring personnel about the
very serious consequences associated with noncompliance and how the new
program automatically helps to assure both regulatory and policy compliance
enterprisewide.
“We’ve tried, with previous employment screening vendors, to integrate with
our payroll system and we’ve had a lot of drawbacks and problems. With
HireRight, if there was a problem, it was fixed immediately,” continued the
company’s director of risk management.
As an additional level of security, the senior care organization has a team of 10 workforce consultants at its national campus who
oversee the entire screening solution. These consultants also check on any background check or sanctions screening results that do not
meet the system’s automated rules and require human review.
Results: Peace of Mind and Ongoing ChecksWith the new HireRight system in place, the national campus can be
assured that the sanctions screening is being done according to policy
at all locations. Corporate staff can run internal audits right from their
desks using HireRight’s screening solution dashboards to ensure that
all individuals on the payroll have been properly screened.
When the solution was implemented, the company ran all of
its current employees through the new sanctions screening
system and received about a dozen indications of potential hits.
After investigating those hits, the central campus found that
five individuals needed to be released. “While five out of 20,000
employees doesn’t sound like a lot, when you think of that number
in terms of a $500,000 penalty per person, you can quickly see the
value in screening and releasing ineligible workers,” explains the
director of risk management.
The company’s management team reflects that the new system has
given its current employees and residents even greater peace of
mind, reassuring them that they will be working and living with
safe, high-caliber individuals.
The director of risk management says that he learned when it comes to
employment screening, nothing should ever be taken at face value. “If
you don’t dig down, then you are never going to find the facts,” he says.
Other screening vendors could not match the
turnaround time, accuracy, high level of coverage and
value which HireRight offered.
““- Director of Risk Management
This HireRight case study is provided for informational purposes only and should not be construed as legal advice. Any statutes or laws cited in this article should be read in their entirety. If you or your customers have questions concerning compliance and obligations under United States or international laws or regulations, we suggest that you address these directly with your legal department or outside counsel.
HireRight Senior Care Case Study 081211PLR
About HireRight
As one of the world’s largest screening providers, HireRight
specializes in helping organizations of all sizes efficiently
implement, manage and control employment screening
programs. Approximately 50,000 organizations, inluding more
than one-third of the Fortune 500, trust HireRight because
the company delivers customer-focused solutions that provide
greater efficiency and faster results. HireRight also provides
pre-integrated employment screening services through
e-recruiting solutions from top providers such as Oracle, Taleo,
Kenexa, SAP, ADP/VirtualEdge, PeopleAdmin, HealthcareSource,
HRsmart and SilkRoad. HireRight, Inc. is an Altegrity company
with worldwide headquarters located in Irvine, California, and
offices and affiliates around the globe. More information can
be found on the company’s website at www.hireright.com.
Getting Started
For more information about HireRight Health Care Employment Screening Solutions, call or visit us online. 800.400.2761 extension 5977 in the U.S. and Canada or +1 949.428.5800 worldwide. www.hireright.com
