Failure to Conduct Pre-Employment Background Checks
Penalty
Summary
The facility failed to ensure the protection of residents from potential abuse by not performing criminal history background checks prior to hiring two employees. The facility's policy mandates that a criminal background check must be submitted to the Pennsylvania State Police before the start of active employment, and applicants cannot be hired or attend orientation until the background clearance is completed. However, the personnel files for a Dietary Aide and a Registered Nurse revealed no evidence of completed background checks before their respective hire dates. During an interview, a Human Resources employee confirmed the oversight, mistakenly believing that the facility had 30 days post-hire to conduct these checks. The employee also mentioned that the facility hesitated to conduct background checks immediately due to concerns about new hires not reporting to work, which would result in wasted resources. This failure to adhere to the established policy potentially exposed residents to individuals who had not been properly vetted for past abuse, neglect, or mistreatment.
Plan Of Correction
1. The facility will ensure that residents are protected from potential abuse by performing criminal history background checks prior to hire for all personnel. The facility cannot retroactively correct the concerns identified with Employees E7 and E12. 2. The Nursing Home Administrator or Designee will re-educate the Human Resources Director on federal regulation 0606, detailing completing criminal background checks prior to hire on all personnel. 3. Criminal history background check audits will be completed weekly for 4 weeks, then monthly for three months to validate criminal background checks are completed prior to hire for all new employees. 4. Criminal background checks were completed for E7 and E12. An audit will be completed on all current staff to ensure criminal background checks were completed. 5. These audits will be forwarded to the monthly Quality Assurance Performance Improvement Committee for review and frequency of audits.