Applicants Must Authorize the Hard Copy of a Disclosure/Release Form

Applicants Must Authorize the Hard Copy of a Disclosure/Release Form

DEPARTMENT: Human Resources / POLICY DESCRIPTION: Background Investigations
PAGE: 1 of 4 / REPLACES POLICY DATED: July 21, 1999; Sept. 1, 1999; Jan. 1, 2002
EFFECTIVE DATE: December 15, 2002 / REFERENCE NUMBER: HR.102
SCOPE: All candidates being hired for the first time or previously employed by an affiliated facility, plus those individuals utilized through a contract staffing agency.
PURPOSE: This policy provides a standard requirement and process for obtaining and evaluating background information in order to make a contingent offer of employment. Such background information may include various components based on the level of responsibility of the position.
POLICY: Offers of employment shall be contingent upon obtaining a signed authorization for the procurement of an investigative consumer report for employment purposes and a satisfactory report. Both the authorization and the report are to be filed in the employee’s personnel file or in a master verification file filed by year and alphabetized for applicants not employed in the facility Human Resources Department. Candidates previously employed by an affiliated facility shall be evaluated for employment based on, among other things, a background investigation that includes, at a minimum, the information consistent with the levels described below.
PROCEDURE:
  1. Notice of Investigation. Applicants shall be provided with notice of the facility’s policy and practice of conducting background investigations before a candidate is hired.
  • Applicants must authorize the hard copy of a disclosure/release form.
  • Facilities should post signs in areas where employment applications are accepted which make clear that the facility has a policy of conducting background investigations for all applicants.
  1. Contingent Job Offer.
  1. New hires: A qualified individual deemed to be the best candidate for a position may be extended an offer of employment contingent upon, at a minimum, the completion of a signed authorization for the procurement of an investigative consumer report for employment purposes and a satisfactory report.
  1. Candidates previously employed by an affiliated facility: A new report will be initiated after a contingent job offer has been made to include a previous employment check from the affiliated facility which previously employed the candidate and other items consistent with the levels later described. It may not be assumed that a thorough investigation was completed by the previous affiliated employer when the candidate was originally hired or that the information disclosed in the original background investigation report will never change over time.
  1. Rehires: If eligible for rehire, a background investigation report will be obtained in accordance with the position level later described. An applicant not eligible for rehire will be considered on a case by case basis and must be approved for employment by the facility Human Resources Department. The approval shall be noted on the Personnel Action Request (PAR) form.
  1. Staffing Agencies, Independent Contractors: Contracts or service agreements must be entered into with all third parties providing temporary or contract employees. The contracts or agreements must address:
i.Stipulation to background investigations based on standards herein.
ii.Liability insurance coverage.
iii.Indemnification.
A background investigation report shall be completed in accordance with the position level later described for individuals who provide services pursuant to contracts with staffing agencies or independent contractors. The contractor must have the completed background investigation report prior to presenting their employee to be utilized.
3.Background Investigation. The facility Human Resources Department will initiate a background investigation after a contingent job offer has been made. All applicants for whom a contingent job offer has been made will have a Level I background investigation. Depending on an applicant’s job responsibilities, a Level II and/or Level III background investigation as described below may also be required:
Level I
Social Security Number Verification

Criminal Search (7 years or up to 5 criminal searches)

Employment Verification (last 7 years)
Violent Sexual offender and predator registry search
OIG List of Excluded Individuals/Entities
GSA List of Parties Excluded from Federal Programs
Government Suspect List

Level II (All professionals, including caregivers, as well as finance personnel, and department managers) –

Social Security Number Verification

Criminal Search (7 years or up to 5 criminal searches)

Employment Verification (last 7 years)
Violent Sexual offender and predator registry search
OIG List of Excluded Individuals/Entities
GSA List of Parties Excluded from Federal Programs
Government Suspect List
Education Verification (highest level)
Professional License Verification
Certification & Designations Check
Professional Disciplinary Action Search
Department of Motor Vehicle Driving history
Consumer Credit Report, if applicable, based on job description/requirements, ordered
separately.
Level III (All senior level management to include Vice Presidents and above, facility CEO, COO, CFO, CNO) –
Social Security Number Verification

Criminal Search (7 years or up to 5 criminal searches)

Employment Verification (last 7 years)
Violent Sexual offender and predator registry search
OIG List of Excluded Individuals/Entities
GSA List of Parties Excluded from Federal Programs
Government Suspect List
Education Verification (highest level)
Professional License Verification
Certification & Designations Check
Professional Disciplinary Action Search
Department of Motor Vehicle Driving history
Consumer Credit Report
Newspaper Articles & Clippings
Bankruptcy and Federal District Court Search
  1. Hiring/Rehiring Ineligible Persons. No affiliated employer shall employ and no staffing agency shall refer to an affiliated facility any Ineligible Person defined as any individual or entity who is currently excluded, suspended, debarred or otherwise ineligible to participate in the Federal health care programs; or has been convicted of a criminal offense related to the provision of health care items or services and has not been reinstated in the Federal health care programs after a period of exclusion, suspension, debarment, or ineligibility.
  1. Analysis of Background Investigation. The facility Human Resources Department shall notify the Hiring Manager if a discrepancy arises between the applicant’s disclosed credentials and the verified information or if the applicant is disqualified for the position based upon the results of the background investigation.
  1. Derogatory information of the following nature as the result of a background investigation may become the basis to no longer consider an applicant qualified for a position:
  1. Conviction of a felony offense; misdemeanor offense, if job related.
  1. Termination from a previous job related to criminal conduct or sexual
predatory behavior.
  1. Inclusion on the list of Ineligible Persons.
  2. Providing a false statement on the application or resume.
  3. A documented financial problem or issue, if job related.
  4. A documented traffic violation, if job related.
This list is not exclusive or exhaustive. Managers should use good judgment when evaluating information obtained through a background investigation report and, when in doubt, consult with the Corporate Employee Relations or Legal Department.
Use of information obtained from a background investigation report must be taken in context with the job for which the applicant has applied. Derogatory information learned from a background investigation report should be considered with all other information known about an applicant, and a case-by-case determination should be made as to the applicant’s suitability for employment. The Human Resources Department or Hiring Manager may seek clarification from the applicant regarding the derogatory information. Information obtained from a background investigation report should remain confidential and not be shared with anyone except on a need to know basis.
  1. The facility Human Resources Department will provide an applicant with the source of credit reporting, as required by the Fair Credit Reporting Act or notify an employee if a decision is made to withdraw a contingent job offer based on derogatory information.
  1. Vendor. Selection is optional to affiliated facilities for background investigation reporting.

REFERENCES:
Limitations on Employment Policy, HR.209
Employment Application
Fair Credit Reporting Rights
Fair Credit Reporting Act Background Research Form

12/2002