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While there are no federal requirements for how a Skilled Nursing Facility (SNF) should screen its employees, these businesses are responsible for keeping its residents physically and mentally safe from offenders. According to the State Operations Manual, Appendix PP, a facility should conduct a thorough “investigation of the histories of … prospective staff,” including checking the State nurse aid registry and licensing authorities, contacting previous employers, attempting to identify prior criminal prosecutions, and checking the Health and Human Service (HHS) Office of Inspector General’s List of Excluded Individuals/Entities (“Exclusion List”). In addition, the Office of Inspector General has issued guidance that urges healthcare providers to check the System for Award Management (SAM) database.

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