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.

For context: 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.

Take note: F-Tag F606 – Not Employ/Engage Staff with Adverse Actions 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. 

Action for facilities:

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.