Background Screening and Exclusion Monitoring

Background Screening and Exclusion Monitoring Policy

Policy Statement

The Company is committed to protecting the health, safety, and welfare of recipients served by the organization, including those funded through Medicaid and other insurance sources, and their families. The Company maintains a background screening and exclusion monitoring process intended to support compliance with applicable Florida Medicaid, AHCA, payer, and professional standards.

This policy establishes general procedures related to background screening, exclusion monitoring, credential verification, and employment eligibility for employees, contractors, volunteers, interns, and other individuals who may provide services to recipients or access protected information.

Scope

This policy applies to:

• Employees
• Contractors
• Volunteers
• Interns
• Consultants
• Clinical staff
• Administrative staff
• Billing personnel
• Individuals who may have direct or indirect contact with recipients or recipient information

This policy applies during:

• Hiring
• Contracting
• Rehire
• Credentialing
• Ongoing employment or engagement

Background Screening Requirements

Level II Background Screening

Employees and contractors providing services to Medicaid recipients or otherwise subject to state screening requirements may be required to complete Level II background screening in accordance with applicable Florida laws, payer requirements, and AHCA standards.

The Company may review:

• Eligibility for employment or engagement
• AHCA screening status
• Disqualifying offenses when applicable
• Compliance with Medicaid participation requirements

Individuals determined to be ineligible under applicable laws, regulations, or payer requirements may be disqualified from employment, reassignment, contracting, or continued engagement.

Multiple Verification Methods

To support recipient safety and regulatory compliance, the Company may verify background and exclusion-related information through more than one source when deemed appropriate.

Verification methods may include:

• AHCA Level II screening
• Employee or contractor attestations of compliance
• OIG exclusion screening
• Florida Medicaid exclusion screening
• SAM.gov screening
• Local criminal record searches
• Employment verification
• Reference checks
• Professional license verification
• Certification verification
• Commercial background screening vendors
• Publicly available records
• Local law enforcement or court records when appropriate

The Company reserves the right to utilize additional verification methods when concerns related to recipient safety, payer participation eligibility (including Medicaid), fraud prevention, or regulatory compliance are identified.

Exclusion Monitoring

The Company may conduct exclusion monitoring prior to hire or engagement and periodically thereafter for applicable personnel.

Screening may include:

• Federal OIG List of Excluded Individuals and Entities (LEIE)

Individuals identified as excluded, suspended, terminated, or otherwise ineligible to participate in federally funded healthcare programs may be restricted from providing Medicaid-funded services or participating in federally reimbursable activities.

The Company may take corrective or administrative action when exclusion concerns are identified.

Employment, Education, and Credential Verification

The Company may verify:

• Employment history
• Professional references
• Educational credentials
• Professional licenses
• Certifications
• Board status when applicable

Credential verification may occur directly through:

• BACB
• State licensure boards
• Educational institutions
• Certifying entities
• Public registries

Documentation related to verification activities may be maintained within personnel or credentialing records.

Frequency of Screening

Background screening and exclusion monitoring may occur:

• Prior to hire or engagement
• During rehire or recredentialing processes
• At intervals required by law, payer requirements, or organizational policy
• Periodically during employment or engagement
• When concerns related to compliance, eligibility, or recipient safety arise

Duty to Report

Employees, contractors, and volunteers may be requested to report matters that could impact:

• Employment eligibility
• Medicaid participation
• Professional licensure or certification
• Recipient safety

This may include:

• Criminal arrests or convictions
• Professional sanctions
• Exclusions
• Investigations involving abuse, neglect, exploitation, fraud, or misconduct

Failure to disclose relevant information may result in administrative review or disciplinary action.

Ongoing Monitoring

The Company reserves the right to:

• Conduct additional screenings
• Request updated attestations
• Review public records
• Reverify credentials
• Conduct compliance-related reviews or investigations

when deemed appropriate to support recipient safety, payer compliance, or organizational operations.

Confidentiality

Information obtained through background screening and verification processes shall be treated as confidential and maintained in accordance with applicable privacy and confidentiality standards.

Access to such information may be limited to authorized personnel with a legitimate operational, compliance, credentialing, or administrative need.

Non-Discrimination

The Company conducts background screening in accordance with applicable federal and state laws and does not unlawfully discriminate based solely on arrest history or criminal history unrelated to:

• Job duties
• Recipient safety
• Professional responsibilities
• Medicaid participation requirements
• Organizational compliance obligations