When it comes to compliance for your next contract, one of the important steps that agencies and/or facilities do is the background screening. This goes for both the national as well as the state level. A previous discussion has covered at length the agency initiated background screening and even the more specific county searches depending on the requirement by the facility. Today we are going to tackle the State requirements that are usually included in the compliance prior to the start.
Please take note that not all contracts or facilities will be going after these requirements. This is also not the complete list of what may be required by a state. Consider this as a heads up in case you are looking into taking up a contract in a given state:
Fingerprinting
Now we know that upon taking up our respective licenses, we are already set up for our fingerprints so this is why not all states require this. However, for those states that do not, you need to work closely with your credentialing specialist in order to get the details of the process. As previously discussed, this can be quite specific depending on how it was required by the facility.
- If you find yourself working in a correctional facility, there is a fair chance that you will be doing this in house. Do not expect that they will also open their database to other entities for your records to be accessed for clearance.
- There are accredited facilities that are assigned for fingerprinting so if you were told that you needed one, do not just go into the first fingerprinting facility near you. Clinical facilities would usually work in coordination with the Department of Homeland Security or the FBI and a fingerprinting vendor in order to get them certified. Therefore, if you do not work with these given entities, your fingerprinting may be considered invalid.
- Always refer back to your compliance specialist for any forms or further instructions on the fingerprinting. There is a fair chance that you might not even have to do an actual fingerprinting. There are some states that refer to the national database and refer to your records from there. This is particularly true for Florida.
- Nevada on the other hand has a different approach. You will be expected to accomplish a form ahead of time and this form is issued from the facility’s end. You will then be given specific instructions and endorsements to a particular fingerprinting facility. Failure to follow will result in a voided transaction.
- Here is the list of the states that would require fingerprinting as part of their compliance:
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- Florida (this is incorporated to the AHCA)
- Nevada
- Pennsylvania
- New York
- North Carolina
- Ohio
- West Virginia
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Education Verification
Almost all the time this is a part of your compliance for a contract prior to start. There are some facilities that would require the submission of your school diploma or your transcript of records and stop there. On the other hand, there are some facilities that would require an actual verification of your details. There are actually two ways that an agency can do this, they can opt for a third party doing the verification like the National Student Clearing House or doing the verification manually on their end. You do not have to concern yourself on how the agency or facility would be going about it but it is important that you understand that this may not be something that can be done within a day.
If an agency does their verification via a third party then there is a pretty good chance that they will get their results in a matter of minutes. There is a chance however that this may take longer depending if the institution readily shares their database with the verification vendor. Worse case scenario, you may have to wait for the result for up to three business days. In the off chance that an institution is not covered by the third party verification, it would really be helpful if you can provide a contact your agency can work with for your verification.
Now let us delve into individual state requirements. As I have mentioned this is not going to be a complete list but these are the more common requirements for the states that we here at Pamela’s list have worked with in the past:
Florida
- The State of Florida will be requiring the AHCA as part of their state requirement. This is basically a quick background screening that immediately refers to the state’s criminal and board of nursing database for any infractions and yes it does include your fingerprinting records.
- In the event that you do not have a record in the AHCA database, you can ask your compliance officer to submit an attestation that you would have to sign in order to buy yourself some time while you process your records for the state. The signed attestation form should give you a 30 day extension.
California
- Requirements from the state are pretty straightforward. It does not have anything specific to the state alone but it does have something that is specific for some facilities (particularly Kaiser and other facilities in and around the greater Los Angeles area). You may be required to get yourself an LA fire safety card.
- This can be set up by doing a seminar. You can work with your charge nurse or supervisor after you have started your contract for scheduling your orientation. You will usually be given 30 days from your start date to complete the said requirement.
- It is also worth noting that CA does not have general state clearance, the next best thing you can do is a federal county clearance.
Colorado
- For travel nurses, the state would require the CAPS report to be run on your behalf. Now as long as there is no hit, you should not have any problems getting cleared for this particular report. This should cover the state’s database for child and elderly abuse. The results for this are almost always instantaneous so this should be a cause of concern or delay. Unfortunately you cannot run this on your end since the agency would have to process their own login just to be able to run the report, not to mention that the report will cost about $10 to run.
Missouri
- There is a state specific report that is usually required if you want to take on a contract in the state. The report is similar to what the state of Colorado looks into. The database is maintained by the DHSS or department of Health and Senior Services.
- The report is called the EDL or employee disqualification list. So the database refers to the list wherein an employee may have been dismissed due to abuse to a client, patient or consumer; misuse of funds and/or falsification of documents.
- As you may have noticed this database is not only for medical professionals but all professionals who are working and have worked in the state. Here is the link to the EDL website: https://www.health.mo.gov/safety/edl/
- A hit on the site will definitely merit a reconsideration on the facility’s end. Coordinate closely with your compliance officer to check on how the facility would actually consider the hit.
State Exclusions
Most usually states can require something as straightforward as state exclusions. Now this is obviously state dependent and they would be maintained as such. Different states would have different approaches when keeping their database. For instance, there are some states that would have specific state exclusions per industry. On the other hand there are some exclusions that compile the results while referring to multiple database from the state (states would usually maintain elderly and child abuse, sex offenders and even a database for any professional infractions).
License Verifications
As part of your requirements, facilities and/or agencies will be looking into the validity of your professional license. Now as long as you do your part in maintaining your license updated and free from any infractions then you do not have any cause of concern.
This is just to let you know how verifications would usually happen on the side of the agency or facility. The general verification is 90% done usually on Nursys. In fact some of the states that do not have their own respective verification system automatically refers you to Nursys. On the other hand there are some states that would utilize their own verification and this is found on the state’s own board of nursing website.
SAM and OIG Exclusions
These are two separate exclusion lists that have become a standard part of the verification that is done in alignment of the ethical standards set in the medical profession. The search is rather instantaneous so this should not be a source of concern if it has to be run at the last minute.
What is OIG?
This is a list of individuals and/or entities that have been excluded by the OIG for infractions. The list is updated on a monthly basis and it is imperative that an establishment would check if their potential hires are in the list or not. If in case that an entity has been found to have hired an individual or had completed dealings with an entity within the exclusion list, they (the facility) may face a fine or CMP (civil monetary penalties.)
What is SAM or GSA (General Services Administration)?
The SAM is relatively the same in nature as the OIG however the SAM focuses its exclusion list on the following database:
- Central Contractor Registry
- Federal Agency Registration
- Online Representations and Certifications Applications
- Excluded Parties List System
This might be confusing since there is certainly an overlap between the two due to how they implement their exclusions list but you can look at this this way, SAM may have a broad coverage in terms of database reference but they do not have any authority to fine any entity unlike the OIG.
You can do your due diligence by doing your own license verification, here is the list of the states and where you can do an online verification of your respective license. This is for free and this is the reference that agencies and facilities use:
If you do not find your state on the list, then you should be able to do your verification through the Nursys portal. https://www.nursys.com/LQC/LQCTerms.aspx
You can also do your respective state exclusions right here:
Now you need to take note that the sites have different ways in completing the state exclusion, you would just have to read and follow the instructions. There are some sites that would allow you to do the search and show you results but there are some where it will give you a file you can download in which you can search for yourself to see whether your name is in the list.
I hope this alleviates some if not all of the apprehensions you may have with regards to compliance. As you can see they can be complex but the things you have to do at the end are pretty simple and straightforward. Next time you get your contract and you find yourself in the compliance process, do not hesitate to ask questions, verify the timeline and ask specifics. Always remember that fear stems from the misunderstood and the unknown.
