Background Checks – Compliance Reminder

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently released an audit report which reviewed compliance with background checks and abuse-registry requirements in skilled nursing facilities. The audit identified instances where staff began working before these required screenings were completed. 

This serves as an important reminder for providers: federal and state regulations require background checks and registry screenings to be completed and documented before an individual begins working in a long-term care facility.  

Regulatory Reminders

F-Tag F606 – Not Employ/Engage Staff with Adverse Actions 

The regulation applies to all staff including employees, contractors, consultants, volunteers, students, and medical directors.  

​F606 requires facilities to not hire or engage individuals with: 

• Court findings of abuse, neglect, exploitation, misappropriation, or mistreatment. 
• State nurse aide registry listings with findings of abuse, neglect, exploitation, misappropriation, or mistreatment 
• Active disciplinary actions against professional licenses for abuse, neglect, exploitation, misappropriation, or mistreatment  

Fair Credit Reporting Act Section 606 – If an investigative background report is ordered, the facility must provide the applicant with a stand-alone written disclosure within three days of requesting the report, along with a summary of their rights under the FCRA. 

Take Action Now

1. Review compliance policies – Confirm that background checks and registry queries are completed before the first day of work. 
2. Update onboarding workflows – Build pre-start verification steps into your hiring process. 
3. Educate hiring teams – Train managers and HR staff on the scope of F-Tag F606, registry checklist requirements, and FCRA timing/disclosure rules. 
4. Include all worker types – Screen not only direct care staff, but also volunteers, contractors, consultants, students, and medical directors. 
5. Document verification efforts – Keep clear records of checks performed for every staff member. 
6. Audit regularly – Conduct routine internal reviews to identify and correct any gaps in compliance. 

Please send any questions to regulatory@ahca.org​.