Customer Success Story

One of the Largest Senior Care Organizations Overhauls Its Screening Program
Industry: Health Care Organization: Long Term Care Challenge: Meeting Federal Employment Screening Regulations
When the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) audited one of the nations largest not-for-profit senior health care providers a few years ago, its management team complied with federal auditors. There was no reason to worry because this senior care organization did everything in its power to ensure the safety and well-being of its more than 20,000 workers and 25,000 patients. The organization was aware of federal regulations that prohibit hiring sanctioned individuals and had dedicated personnel at each of its 240 U.S. facilities, checking every job candidate against the OIG List of Excluded Individuals/Entities (LEIE). It even partnered with a background screening vendor to run criminal checks on all applicants. Yet, during a routine federal audit, authorities uncovered one current employee with outstanding sanctions who was prohibited from working for health care providers that accept federal funds. In the end, the government fined the senior care organization $500,000 and warned that if the organization did not improve its employment screening system and auditors found future violations, the fines would increase.

Hidden Risks Inherent in the Screening Program

It may seem that the OIG has a straightforward solution for preventing sanctioned individuals from being employed in health care, but there are a few big challenges to meet its requirements. 1) There may be time gaps between when a person is sanctioned at the state level and when that offense is reported up to the federal level and published on the OIG LEIE.

2) Individuals can alter their names, change locations and falsify identifying

While five out of 20,000

information, such as Social Security numbers, in order to hide past sanctions. 3) Many large health care organizations employ thousands of workers, which increases the chance for lapses in screening and mistakes due to human error. After the audit, it became clear that immediate changes to the organizations screening program were necessary. The audit prompted the senior care organization to partner with Kroll, now a HireRight company, to design and implement a comprehensive employment screening program. Other screening vendors could not match the turnaround time, accuracy, high level of coverage and value which HireRight offered, commented the companys director of risk management.

employees doesnt sound like a lot, when you think of that penalty per person, you can

number in terms of a $500,000

quickly see the value in screening and releasing those workers.

- Director of Risk Management

Hire Safe. Hire Smart. HireRight.

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HireRight uncovered several weaknesses in the providers previous employment screening program. The old employment screening process was too decentralized. Hundreds of employees at 240 different locations across the country handled sanctions screenings with no central system to double-check the work for human error. Further, there was no way to discover aliases or maiden names used by applicants under which they may be sanctioned. Like most large decentralized health care employers, this senior care organization found that many individuals responsible for hiring were unaware of regulatory requirements related to employment screening and the penalties for an oversight. Workers were also unaware of the risk to the organizations brand caused by employing sanctioned workers. Finally, although the organization had sanctions screening and criminal background checks in place, these checks were only meeting the minimum regulatory obligations. In order to account for transient workers, name changes, false identifying information and time gaps between state sanctions and federal reporting, the organization needed to greatly increase the scope of its screening.

Health Care Hiring Regulations

Federal guidelines set up by the Office of Inspector General (OIG) prohibit health care organizations from hiring workers with outstanding sanctions and violations. If a health care organization is found to employ even one sanctioned worker, it can be subject to severe fines, be ordered to reimburse the government for services provided by sanctioned workers, be placed under strict oversight by federal auditors, and may lose its ability to receive federal funding through Medicare and Medicaid.

HireRight Builds a More Centralized, Consistent and Efficient Health Care Employment Screening Program
To strengthen its program, the organization centralized its employment screening processes through an automated web-based screening platform integrated with its applicant tracking system. As recommended by HireRight, the organization changed the way it screened candidates and employees by layering a complete criminal history check on top of robust sanctions and exclusions screening.

The organization expanded its criminal records searches beyond the state where the hiring location is based to include every location the applicant had lived in for the previous seven years. Further, it expanded its sanctions database screening program by comparing the name used by the applicant on his or her employment application and all other names associated with the applicants Social Security number against the OIG LEIE and U.S. General Services Administration (GSA) Excluded Parties List System (EPLS). The new employment screening program also runs the job candidates name and other identifiers through national databases for positive matches related to criminal activity or sanctions and exclusions violations. This broader search helps to ensure that red flags in a candidates history are uncovered.

For increased efficiency, the employment screening process was

The companys management team

integrated with the organizations Lawson payroll system. A human resources staff member at each of the 240 centers enters a new hires basic information into the payroll system. Any new payroll data is automatically detected and uploaded to the employment screening solutions central database several times a day. The employment screening solution then runs the new hire data through the series of background and sanction checksa process that typically takes one to two days to complete. The senior care hiring personnel can access a centralized and simple dashboard where they can monitor the status of their

reflects that the new system has given

its current employees and residents even greater peace of mind, reassuring them safe high-caliber individuals.
- Director of Risk Management

that they will be working and living with

Hire Safe. Hire Smart. HireRight.

SM

new hires and see when someone is cleared in real-time. Further, the organization, with HireRights help, educated its hiring personnel about the very serious consequences associated with noncompliance and how the new program automatically helps to assure both regulatory and policy compliance enterprisewide. Weve tried, with previous employment screening vendors, to integrate with our payroll system and weve had a lot of drawbacks and problems. With HireRight, if there was a problem, it was fixed immediately, continued the companys director of risk management.

Other screening vendors could not match the turnaround time, accuracy, high level of coverage and value which HireRight offered.
- Director of Risk Management

As an additional level of security, the senior care organization has a team of 10 workforce consultants at its national campus who oversee the entire screening solution. These consultants also check on any background check or sanctions screening results that do not meet the systems automated rules and require human review.

Results: Peace of Mind and Ongoing Checks

With the new HireRight system in place, the national campus can be assured that the sanctions screening is being done according to policy at all locations. Corporate staff can run internal audits right from their desks using HireRights screening solution dashboards to ensure that all individuals on the payroll have been properly screened. When the solution was implemented, the company ran all of its current employees through the new sanctions screening system and received about a dozen indications of potential hits. After investigating those hits, the central campus found that five individuals needed to be released. While five out of 20,000 employees doesnt sound like a lot, when you think of that number in terms of a $500,000 penalty per person, you can quickly see the value in screening and releasing ineligible workers, explains the director of risk management. The companys management team reflects that the new system has given its current employees and residents even greater peace of mind, reassuring them that they will be working and living with safe, high-caliber individuals. The director of risk management says that he learned when it comes to employment screening, nothing should ever be taken at face value. If you dont dig down, then you are never going to find the facts, he says.

About HireRight
As one of the worlds largest screening providers, HireRight specializes in helping organizations of all sizes efficiently implement, manage and control employment screening programs. Approximately 50,000 organizations, inluding more than one-third of the Fortune 500, trust HireRight because the company delivers customer-focused solutions that provide greater efficiency and faster results. HireRight also provides pre-integrated employment screening services through e-recruiting solutions from top providers such as Oracle, Taleo, Kenexa, SAP, ADP/VirtualEdge, PeopleAdmin, HealthcareSource, HRsmart and SilkRoad. HireRight, Inc. is an Altegrity company with worldwide headquarters located in Irvine, California, and offices and affiliates around the globe. More information can be found on the companys website at www.hireright.com.

Getting Started
For more information about HireRight Health Care Employment Screening Solutions, call or visit us online. 800.400.2761 extension 5977 in the U.S. and Canada or +1 949.428.5800 worldwide. www.hireright.com

This HireRight case study is provided for informational purposes only and should not be construed as legal advice. Any statutes or laws cited in this article should be read in their entirety. If you or your customers have questions concerning compliance and obligations under United States or international laws or regulations, we suggest that you address these directly with your legal department or outside counsel.

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An Altegrity Company
Copyright 2011 HireRight, Inc. All rights reserved. HireRight Senior Care Case Study 081211PLR

HireRight is an Altegrity Company. Certain Altegrity companies provide investigative services. State licensing information can be found at www.altegrity.com/compliance.