Why Your Home Health Care Agency Needs More Than a “Standard” Background Check in 2026
Turnover is high, regulations are shifting, and your team works in the most trust-dependent environment there is: a patient’s home. In 2026, you can’t rely on a one-size-fits-all package. You need an approach that balances speed, compliance, and risk. If you’re hiring this year, make sure your process is anchored in FCRA-compliant employment background checks designed for home-based care.
Quick Summary
- Caregiver turnover remains near 80% nationally, so you must hire fast without cutting corners.
- “Standard” packages miss administrative sanctions and state-level exclusions—high risk for HHC.
- For licensed roles, pair FACIS III with LEIE checks and ongoing monitoring to protect reimbursement.
The 2026 Reality Check: Turnover, Cost-Per-Hire, and Compliance Pressure
Home care turnover has hovered near 80%, according to recent benchmarking from the Home Care Association of America and Activated Insights. HCAOA’s 2024 summary cited 79.2% caregiver turnover in 2023. At the same time, SHRM’s 2025 benchmarking pegs average non-executive cost-per-hire at $5,475. That math pressures agencies to move fast.
Meanwhile, Clean Slate and Fair Chance policies continue to expand. Sealed records and state-specific rules change what you can consider and when. Your screening flow must be accurate, job-related, and timed correctly.
Takeaway: You need faster hiring without skipping the non-negotiables.
The Home Setting = High Trust and Low Supervision
Home health is different. Your staff has unsupervised access to vulnerable patients, medications, and sometimes financial information. Add the “state-hopper” effect—nurses and aides moving across state lines—and local-only searches can miss critical history.
Criminal-only checks won’t catch non-criminal license problems. Board of Nursing discipline is administrative, so sanctions may not appear in criminal courts. See the National Council of State Boards of Nursing’s overview on board actions to understand why professional screening is essential.
Takeaway: If it isn’t built for home-based care, it isn’t enough.
What “Standard” Misses: FACIS I vs. FACIS III and OIG’s LEIE
Many agencies rely on FACIS I plus a basic criminal search. The problem: FACIS I primarily covers federal lists. By contrast, FACIS Level III aggregates thousands of federal and state sources, including state Medicaid exclusions and board sanctions across all U.S. jurisdictions. That’s how you catch disciplinary actions that never became criminal charges.
Pair this with OIG’s List of Excluded Individuals/Entities (LEIE). OIG warns that employing excluded individuals can trigger civil monetary penalties and urges routine LEIE checks. Review OIG’s guidance and search tool on the Exclusions page.
For context, OIG announced a $1.56M settlement in May 2025 with facilities that employed excluded individuals—illustrating how costly a miss can be for any provider billing federal programs.
Takeaway: For licensed clinicians, FACIS III + LEIE screening is the floor, not the ceiling.
Role-Based Screening Packages That Work in Home Health
One package for every role is a mistake. Match screening depth to the job’s risk.
Entry-Level & Non-Clinical (HHAs, Companions, Admin)
- Identity & integrity: SSN Trace,
- Multi-jurisdictional criminal database +
- 7 Yr county criminal searches,
- National Sex Offender Registry.
- Healthcare exclusions: FACIS I and OIG
- When driving is involved, add MVR and employment verifications.
Licensed Clinical Staff (RNs, LPNs, PT/OT, Therapists)
- Everything above, plus
- Professional License Verification from the primary source
- FACIS III
- Federal Criminal Search,
- Education Verification,
- Employment Verification
- Drug Testing
- When driving is involved, add MVR and employment verifications.
Takeaway: Build packages per role and risk profile.
A Quick Case Study: The Cost of a “Standard” Search
The scenario: A mid-sized agency hires an RN who moved states. The agency runs a criminal search and FACIS I; both look clear. Six months later an audit surfaces a prior Board of Nursing sanction for drug diversion—an administrative action, not a criminal conviction.
The fallout: The agency faces repayment on claims tied to that nurse and legal spend during remediation. This is the same risk pattern OIG warns about with exclusions and sanctions (LEIE guidance and the 2025 settlement).
The fix: Use FACIS III, verify licenses from the source, and turn on ongoing exclusion/license monitoring, especially for clinicians.
Takeaway: Administrative sanctions are invisible to criminal-only checks.
Avoid the Big Mistakes: Clean Slate, Adverse Action, and “Instant” Databases
- Don’t rely on instant-only sites. Database hits must be verified at the source to be used for employment under the FCRA. Build a workflow that confirms records at the county or court of record.
- Follow the Adverse Action steps. Send pre-adverse notices with the report and the FCRA Summary of Rights, allow time for disputes, then issue the final notice if needed. See EDIFY’s glossary: pre-adverse action and adverse action.
- Plan for Clean Slate. As more states expand Clean Slate/Fair Chance frameworks, some older or lower-level records may be sealed. Keep decisions job-related and consistent with business necessity and check current state rules.
Takeaway: Compliance isn’t optional—especially if you bill Medicare/Medicaid.
FAQ
Q: What’s the difference between FACIS I and FACIS III?
FACIS I focuses on federal sources. FACIS III adds thousands of state boards, state Medicaid exclusions, and disciplinary actions—vital for clinicians. Learn more from Verisys. Next step: map FACIS levels to your roles.
Q: How often should we check the OIG LEIE?
A: OIG urges routine LEIE checks for new hires and current staff to avoid civil monetary penalties. See OIG’s Exclusions page. Next step: add ongoing LEIE monitoring to your workflow.
Q: Do Clean Slate laws mean we can’t see serious offenses?
A: Not necessarily. Clean Slate typically seals specific eligible records. Serious, recent, or disqualifying offenses may remain reportable depending on state law and screening scope. Next step: align your decision matrix with current state rules.
Q: What is “continuous monitoring,” and is it required?
A: Many NCQA-aligned programs perform ongoing monitoring of licenses and exclusions between recredentialing cycles. See NCQA’s updates. Next step: implement monthly checks for licensed roles.
Q: How do we legally reject a candidate based on the report?
A: Follow the FCRA’s two-step adverse action process: pre-adverse notice with report and rights, a reasonable waiting period, then final adverse notice if confirmed. See EDIFY’s FCRA Summary of Rights. Next step: have templated notices ready.
Why Partner with a Trusted CRA Like EDIFY Screening?
- Compliance expertise: We stay ahead of 2026 state rules and federal guidance, and we can run your adverse action process properly.
- Primary-source data: We verify at the court or licensing board, and we pair FACIS III + LEIE for clinical roles.
- Human support: You get a dedicated team that explains results and helps you make job-related, consistent decisions.
Takeaway: A thoughtful, role-based program protects patients, staff, and reimbursement.
Conclusion
Your reputation rides on every shift in the field. Move beyond a checkbox approach, reduce risk, and hire confidently. Ready to tighten up your program? See our background check pricing and we’ll tailor the right HHC packages for 2026.
Compliance Note
- Use the FCRA two-step adverse action process with the FCRA Summary of Rights.
- Verify records at the primary source before using them in hiring decisions; avoid “instant-only” databases.
- For clinical roles, include LEIE screening to protect Medicare/Medicaid reimbursement (OIG Exclusions).
Related Terms
Authoritative Sources
Internal links inserted:[FCRA-compliant employment background checks → https://www.edifyscreening.com/general_business_background_checks/];[Small business background checks → https://www.edifyscreening.com/small_business_background_checks/];[See our background check pricing → https://www.edifyscreening.com/background_check_pricing/]
