Strengthening Employee Screening

Lessons from Recent OIG Audit Findings

 

A recent audit by the U.S. Department of Health and Human Services Office of Inspector General (OIG) revealed serious gaps in verifying nursing home staff background checks in Alabama. While the audit focused on one state, the implications are far-reaching and relevant for operators nationwide.

 

Key Findings from the OIG Audit (Alabama Audit A-04-24-08104)

The audit examined nursing home compliance between January 1, 2022, and April 8, 2024, reviewing 439 employees across sampled facilities. It was discovered that 139 employees did not have properly verified background checks or registry queries performed before beginning work.

Based on these findings, the OIG made four strong recommendations to the Alabama Department of Public Health (ADPH), urging:

  1. Implementation of a process to verify background checks and registry queries before employee onboarding.
  2. Education efforts to inform facilities about the critical importance of timely background verification.
  3. Requirement for facilities to establish formal policies and procedures for registry queries prior to employment.
  4. Conducting ongoing reviews of facility compliance with these requirements.

As of now, all four recommendations remain open and unimplemented, with further action expected by early 2026.

 

Broader Implications & Why This Matters Across States

Although this audit focused on Alabama, the risks and lessons apply universally:

  • Nursing home residents rely on trusted, screened staff. Lapses in background verification can significantly compromise safety.
  • Other states may face similar audits, and the trend toward heightened oversight is increasing, especially around employee screening procedures.
  • Like Alabama, other states could be prompted to institute mandatory pre-employment verification, backed by audits or sanctions.
  • Facilities lacking consistent background screening could face reputational damage, regulatory action, or worse.

 

Are you Compliance Ready?

 

Compliance ItemSuggested Action Item
Policy Audits & Gap AnalysisReview your current employee screening processes and identify areas vulnerable to OIG scrutiny.
Custom Procedure DevelopmentDraft and implement clear, state-compliant procedures ensuring registry and background checks are completed before onboarding.
Staff Education & TrainingDevelop trainings for HR and leadership teams on regulatory expectations and best practices.
Compliance Monitoring ToolsOffer checklists to track completion rates and trigger follow-up actions for missing verifications.

 

The OIG audit serves as a reminder that compliance cannot be reactive and instead must be built into daily operations. Nursing homes that establish robust, proactive screening processes not only reduce regulatory risk but also strengthen trust with residents, families, and communities. By taking action now, providers can position themselves as industry leaders in both resident safety and regulatory readiness.


Written by:

Sheena Mattingly, M.S., CCC-SLP, RAC-CT  |  Executive Vice President of Quality & Compliance, HTS