Medical Background Checks: How to Discuss Continuous Monitoring in Your Employee Handbook
Continuous monitoring allows your organization to track license activity and search for healthcare employment exclusions on an ongoing basis. It delivers real-time updates about the workforce, so you can stay well-informed about employment sanctions, debarments, and other activities impacting an individual’s ongoing continued employment. Continuous monitoring also picks up where your pre-employment background screening left off, helping you manage risk and protect your workplace.
The employee handbook is an ideal place to educate employees about your screening policies and keep them informed of policy changes or other enhancements over time. Here are some ideas to help you educate your workforce about medical background checks and continuous monitoring.
Why the Employee Handbook?
Your employee handbook contains a description of the HR policies and practices employees encounter during their employment with your organization. As the centralized source of employment information, your handbook is where employees go to learn the dos and don’ts of their employment experience. Though you must satisfy Fair Credit Reporting Act (FCRA) requirements for disclosure and authorization separately, your handbook is a great place to give employees information about your background screening policies and processes.
Your employee handbook relays the mission, values, and culture of your organization. It describes processes for protecting the workforce and others, including patients and visitors. For example, in describing safety procedures in the workplace, the handbook expresses the steps you take to prevent illness and injury and what employees need to do to avoid accidents. The handbook gives you the opportunity to show how your continuous monitoring activities align with your goal of maintaining a safe work culture.
Your employee handbook is also a living document for the workforce. As changes in policy and practice occur, you likely update your handbook routinely to keep it current. According to an XpertHR survey, 78 percent of businesses have made revisions to their handbook within the previous two years. Since your handbook is possibly one of the most updated employee documents in your HR toolkit, it is an ideal source for your background screening and continuous monitoring procedures.
Aspects of Continuous Monitoring to Cover in Your Handbook
The many sections of your employee handbook probably follow a similar structure, with each policy description answering basic questions such as why, what, where, how, and who. To be sure you’re providing a well-rounded picture of your screening program, you can start by answering those questions and adding more detail where necessary. Here are some of the aspects of your continuous monitoring program you’ll want to include:
- Why is the organization using continuous monitoring, and what will it accomplish? This is your opportunity to explain the purpose of continuous monitoring as well as its benefits.
- What aspects of an employee’s background will be checked? You can explain the specific lists and databases you will include in ongoing monitoring.
- What is the process for self-reporting or correcting erroneous information from a background search? Explain the steps for submitting new or corrected background information.
- In cases where monitoring results could impact a person’s ongoing employment, what is the adverse action process? Describe your adverse action policy and employee rights to review screening results.
- Where can employees go to find updated disclosure and authorization documents, and other information describing continuous monitoring activities? You can provide copies of disclosure documents and describe where employees can go to obtain related policy documents, for example, your intranet or centralized document library.
- How will the organization protect employee privacy? You can describe your process for keeping employee authorizations and other data secure.
- How will the organization communicate policy changes and updates? Explain how you will communicate updates, either via email, an addendum to the employee manual, or by other means.
- Who will conduct the monitoring? You can provide details about the reputable background screening provider conducting continuous monitoring for the organization.
- Who are the key points of contact for questions? Possible internal contacts may include HR, compliance, or legal.
Benefits of Including Continuous Monitoring in Your Handbook
When employees understand the purpose of continuous monitoring, they are more likely to trust it. Without a clear explanation of how monitoring is conducted—and why—employees may believe there is an ulterior motive or their privacy will be violated. On the contrary, when you define and communicate your policies for medical background checks and continuous monitoring, employees have a chance to understand how ongoing screening is conducted and the steps you are taking to protect the workplace.
Background screening is an important part of your hiring and compliance processes, and it has a far-reaching impact on everyone who comes in contact with your organization. Explaining your screening and monitoring policies in your handbook also helps you to achieve specific benefits for employees. When you include continuous monitoring in your employee handbook, you are taking steps to make improvements in the following areas:
When you provide information about your procedures for medical background checks, you help employees see how the organization satisfies legal requirements and pursues best practices for your industry. By fully explaining your continuous monitoring activities, you help employees know how the program works, its purpose, and where they can go to get more information. With a plentiful supply of information and resources, employees have the chance to see continuous monitoring not as a way to “catch” employees in wrongdoing, but as a way to protect employees, patients, and the organization as a whole.
Creating trust in the workplace
Trust is at the heart of a positive employment relationship. According to a study by the Center for Neuroeconomics, employees in high-trust work environments report 50 percent higher productivity and 76 percent more engagement. Helping employees understand the procedures and positive outcomes of continuous monitoring allows them to feel part of the process and not alienated by it.
In addition to describing the parameters of your continuous monitoring program in your employee handbook, you can encourage greater trust in the workplace through the following related actions:
- Clearly explaining new updates to the continuous monitoring program
- Applying monitoring consistently throughout the organization
- Respecting employee privacy rights
Meeting compliance obligations
Healthcare employers are responsible for searching several sanction lists and databases as part of a complete medical background check. But your compliance obligations don’t end with pre-employment background screening. The Department of Health and Human Services (HHS) Office of Inspector General (OIG) requires healthcare employers to check exclusion and sanction lists routinely for employee names. Those lists include:
- HHS OIG List of Excluded Individuals and Entities (LEIE)
- U.S. General Services Administration (GSA) System for Award Management (SAM)
- U.S. Treasury Office of Foreign Asset Control (OFAC) database
Your employees may not be aware of the many compliance obligations your organization must meet to protect patients and others. By discussing continuous monitoring in your employee handbook, you help employees see how essential your monitoring activities are to the overall compliance standing of the organization.
Managing talent management risks
Your employee handbook describes standards for employee behavior at work. Including a comprehensive section on continuous monitoring gives you an opportunity to link your background check activities to broader organizational goals for the reduction of malpractice, unlicensed activity, and unnecessary injury.
Protect Your Workplace with Continuous Medical Background Checks
Your employee manual is so much more than a collection of policies. It provides you with a unique opportunity to educate employees and build a more robust understanding of your continuous monitoring activities. With the help of your background screening partner, you can conduct real-time, ongoing monitoring of your workforce while maintaining trust and transparency in your talent management processes. To protect your healthcare workforce and stay in compliance with applicable laws and guidelines for continuous exclusion monitoring, get started with our background screening compliance checklist.