A Fraud and Abuse Control Information System (FACIS) background check identifies individuals in the healthcare field who have been debarred or suspended due to fraud, abuse, or other wrongdoings.
At iprospectcheck, we regularly conduct FACIS background checks for employers across the nation.
Here’s what you should know about these types of searches and their importance.
KEY TAKEAWAYS
• A Fraud Abuse Control Information System (FACIS) check searches numerous databases at the federal and state levels to identify individuals and entities that have been debarred and excluded from performing work on federal healthcare contracts.
• Healthcare organizations conduct FACIS searches to ensure compliance, protect patient safety, and prevent the loss of their contracts.
• Failing to perform FACIS checks could expose organizations to substantial penalties and fines and could result in the loss of their ability to contract with Medicare, Medicaid, and other programs.
• In addition to FACIS checks, healthcare employers should conduct a variety of other types of background searches to ensure they receive robust information about each applicant.
What is a FACIS (Fraud Abuse Control System Information) Search?
A FACIS background check searches more than 5,000 sources to provide information about a candidate’s debarments, sanctions, exclusions, suspensions, or other disciplinary actions from state and federal sources within the 50 US states and 6 US territories.
FACIS background checks help healthcare providers avoid hiring individuals who have been debarred, excluded, or suspended and cannot work for employers with federal or state healthcare contracts.
Why Conduct a FACIS Check?
A FACIS background check can help organizations ensure compliance, protect patient safety, and mitigate financial and reputational risks.
Here is why you should consider conducting FACIS checks on your applicants and existing employees:
1. Improved Patient Safety
A FACIS check reveals if an individual has engaged in patient abuse, neglect, or financial exploitation.
Performing a FACIS background check on every prospective candidate, volunteer, and vendor can protect the patients your healthcare organization serves.
2. Mitigate Risks of Healthcare Fraud
Healthcare organizations face significant risks of being the victims of fraud.
The U.S. Sentencing Commission reported 57,857 healthcare fraud cases in the fiscal year 2021 with a median loss of $1,002,407. Out of these cases, 17.3% involved losses of more than $9.5 million.
FACIS checks helps your organization avoid hiring individuals who have been convicted of fraud.
3. Ensure Regulatory Compliance
Under guidance from the Office of the Inspector General (OIG) for the U.S. Department of Health and Human Services (DHHS), healthcare organizations that contract with Medicare and Medicaid are prohibited from contracting with entities or hiring individuals who have been excluded from participating in federal healthcare programs except under limited circumstances.
4. Protect Your Reputation
Employee misconduct can quickly harm the reputation of an organization.
Conducting FACIS checks and other types of employment background checks, such as criminal history searches, employment verifications, education verifications, professional license verifications, and Social Security Number (SSN) traces, can provide you with a holistic picture of each applicant so that you can make better hiring decisions and safeguard your organization’s brand.
Which Healthcare Professionals Should be Screened?
Healthcare organizations should conduct FACIS checks on prospective candidates in the following healthcare roles and more:
- Licensed practical nurses (LPNs)
- Registered nurses (RNs)
- Medical doctors (MDs)
- Doctors of osteopathy (DOs)
- Doctors of chiropractic (DCs)
- Doctors of dental medicine (DDMs)
- Registered dieticians (RDs)
- Doctors of optometry (ODs)
- Audiologists
- Speech therapists
- Speech pathologists
- Radiologists
- Licensed professional counselors (LPCs)
- Psychologists
- Acupuncturists
- Physical therapists
- Clinical laboratories
- Ophthalmologists
- Pharmacies
- Doctors of pharmacy (PHARM-Ds)
- Physician assistants (PAs)
- Nurse practitioners
- Emergency medical technicians (EMTs)
- Paramedics
- Respiratory therapists
- Ambulance companies
- Social workers
- Certified Nursing Assistants (CNAs)
- Others
FACIS Level 1 vs Level 3 Background Checks: What are the Differences?
There are two options for FACIS background checks: Level 1 and Level 3.
FACIS level 1 meets the minimum regulatory requirements but does not include as many data sources.
FACIS level 3 exceeds the federal requirements and searches many more data sources.
Here’s a breakdown of both options.
FACIS Level 1 Search
A FACIS Level 1 search is the baseline to ensure compliance by organizations that receive government funding.
In this search, data is sourced from the following:
- OIG List of Excluded Individuals/Entities (LEIE)
- Drug Enforcement Administration (DEA)
- Department of the Treasury Office of Foreign Asset Control’s List of Specially Designated Nationals (OFAC-SDN)
- Food and Drug Administration
- Medicare Opt-Out
- Tricare
- State Medicaid sanctions lists
- State debarments
- State attorney general notice and release sources
Some examples of healthcare professionals that should undergo a FACIS Level 1 search include:
- EMTs
- Paramedics
- Medical social workers
- Dieticians
- Nutritionists
FACIS Level 3 Search
Level 3 FACIS checks search the databases from Level 1 as well as information from additional state sources and debarment lists.
These include sanctioning boards in all states and U.S. territories, HEAT task forces, federal U.S. attorneys, state attorney generals, and more.
The following are examples of healthcare professionals who should undergo FACIS Level 3 checks:
- Certified Nursing Assistants
- Nurses
- Nurse practitioners
- Physician assistants
- Pharmacists
- Psychologists
- Licensed professional counselors
- Medical doctors
- Doctors of osteopathy
- Doctors of chiropractic
- Clinical laboratories
- Ambulance companies
How Can I Obtain a FACIS Report?
Healthcare organizations can attempt to approximate the information included in FACIS by sending requests to numerous agencies and searching publicly available online databases.
However, a do-it-yourself approach is not a good idea because of the challenges involved with obtaining accurate information and maintaining regulatory compliance.
The best method of completing this type of background check is to partner with a reliable third-party background check provider like iprospectcheck.
We can conduct thorough FACIS checks on all of your prospective candidates, new hires, and current employees.
We also offer a variety of employment background checks to give you a complete view of each candidate before making a hiring decision.
5 FACIS Background Check Best Practices
1. Provide Notice and Obtain Written Consent
Before conducting any type of employment background check, you must inform your applicants and employees of your intention to do so as per FCRA requirements.
This notice must be in writing and included in a standalone form.
After your applicants have reviewed the disclosure, you need to ask for their written consent before you can conduct a background check.
You can include the consent form as a part of the disclosure. Make sure your applicant signs and dates it before conducting your background checks
2. Know When to Perform FACIS Checks
You should perform FACIS checks before hiring a candidate, prior to a new hire’s appointment date, and on an ongoing basis after an employee has been hired.
Each month, the database is updated with over 75,000 new records, so it’s essential to perform a check again just before a new hire’s start date to confirm new negative information has not been reported.
3. Conduct Other Types of Background Checks
Healthcare professionals have a significant amount of contact with vulnerable patients and should undergo thorough screening.
In addition to a FACIS check, consider conducting the following types of background screens:
- Criminal history search
- Employment verification
- Education verification
- Professional license verification
- SSN trace
- Sex offender registry search
- National watch list search
- Pre-employment drug screen
4. Individually Assess Conviction Records
Suppose you discover an applicant has a criminal record but is not debarred or excluded.
In that case, you must still individually assess the conviction as it relates to the job for which the applicant is under consideration before you decide against hiring them.
5. Complete the Adverse Action Process
If you decide you don’t want to hire an applicant based on the information you learned from the background check, the FCRA requires you to complete the adverse action process.
Send a pre-adverse action notice to the applicant in which the problematic information is identified. Include a copy of the background check report.
Give the applicant five days to provide mitigating evidence or contest the information.
If you still want to deny employment, send a final adverse action notice. Include a copy of the individual’s rights under the FCRA and state law.
iprospectcheck: Your Trusted Partner for FACIS Checks
Healthcare organizations should include FACIS checks as a regular part of their employment screening process.
Performing these checks can help to identify people who have been barred from working in the healthcare sector and protect your patients, employees, and organization.
At iprospectcheck, we conduct FACIS checks for healthcare employers on a regular basis.
Request a free consultation today. Call (888) 509-1979
DISCLAIMER: The resources provided here are for educational purposes only and do not constitute legal advice. Consult your counsel if you have legal questions related to your specific practices and compliance with applicable laws.
