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In today’s fast-paced environment, senior living facilities often feel pressure to hire quickly to fill critical roles. While efficiency is important, speed should never come at the expense of safety and regulatory compliance.

A thorough screening process must be completed before orientation begins. This process includes conducting background checks, reviewing results, verifying professional licenses, checking references, and confirming all required credentials. These steps help ensure every individual meets regulatory and organizational standards, which aids in protecting residents and the facility.

Establish a strong policy and procedure

Every facility should have a clear, structured policy outlining these requirements for all individuals who interact with residents—employees, contractors, volunteers, consultants, and students. Centers for Medicare & Medicaid Services (CMS) guidance emphasizes that “staff” encompasses all these roles, so screening must be consistent across the board.1

Streamline and audit the process

Hiring often involves multiple stakeholders, which can lead to missed steps without a standardized system. A checklist-driven onboarding process helps maintain consistency and compliance. Beyond initial screening, facilities should implement ongoing controls, such as:

  • Audit background check documentation regularly for all employees to ensure files are complete, accessible and current. This helps confirm only qualified individuals care for residents.
  • Standardize reference checks and license verifications using standardized questions or criteria for all candidates ensure consistency in identifying concerns that could impact resident safety.
  • Track state-required rechecks, as many states require periodic rescreening to maintain compliance.

Regulatory requirements and risks

CMS prohibits hiring individuals with findings of abuse, neglect, exploitation, or misappropriation of property, as well as those with disciplinary actions against their license. Screening should apply to all positions—even non-direct care roles.

States may impose additional restrictions, and some facilities choose to adopt stricter hiring standards than required. The State Survey Agency may also enforce compliance through programs like the National Background Check Program or state-specific licensure requirements. Failing to implement a thorough screening and monitoring process can lead to serious consequences, including harm to residents and regulatory penalties.

A proactive, well-documented screening program is an effective way to protect residents and reduce organizational risk. Facilities should review their current policies, confirm that their screening steps are consistent, and ensure they have a system in place for ongoing monitoring.

[1] CMS State Operations Manual, Appendix PP: Guidance to Surveyors for Long Term Care Facilities, https://www.cms.gov/medicare/provider-enrollment-and-certification/guidanceforlawsandregulations/downloads/appendix-pp-state-operations-manual.pdf.

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