Federal regulation 42 CFR 483.12(a)(3) provides beneficiaries who rely on long-term care services with protection from abuse, neglect, and theft by preventing prospective employees with disqualifying offenses from being employed by these care providers and facilities. The National Background Check Program was enacted by legislation in 2010 to assist states in developing and improving systems for conducting federal and state background checks. Prior OIG work has shown that not all states complied with the National Background Check Program for Long-Term Care Providers.

The OIG has added background checks for nursing home employees to their workplan for 2021 to determine whether Medicaid beneficiaries in nursing homes in selected States were adequately safeguarded from caregivers with a criminal history of abuse, neglect, exploitation, mistreatment of residents, or misappropriation of resident property.

We have all been burdened with the COVID-19 battle, however, we can’t let our guard down on the essential processes and systems we have in place to protect our residents. The government certainly hasn’t, and rightfully so! Take a few minutes and audit your employee files to be sure that background checks are indeed being done per your policy. If you find that there is a deficient practice (i.e., not following policy), report to the QAPI committee for recommendations. Remember, it takes a village so delegate the task but don’t ignore it!

Stay the course, stay well, get vaccinated, and stay tuned!