Failure to Complete Pre-Employment Background and Registry Checks for Staff
Penalty
Summary
The facility failed to conduct required background checks, Nurse Aide Registry (NAR) reviews, abuse registry checks, and reference checks for multiple employees prior to hire. Personnel files for several staff members, including CNAs, LPNs, and an activities assistant, lacked evidence of these checks. In some cases, the background check log did not include the employees, indicating that no background check was completed. The facility also failed to maintain a complete and accurate background check log, with some logs missing information for staff hired prior to certain years. Interviews with the Human Resources (HR) Director confirmed that reference checks were not completed prior to hire, and that the facility's practice was to proceed with hiring after two unsuccessful attempts to contact references. The HR Director also confirmed that there was no evidence of NAR or abuse registry checks for several employees. In one instance, a background check found in a personnel file did not belong to the employee in question. The HR Director stated that missing documentation was due to previous HR management and changes in facility ownership, resulting in lost files and incomplete records. The Administrator and Regional Director of Operations (RDO) demonstrated a lack of understanding regarding the difference between the abuse registry and the NAR, with the Administrator stating she thought they were the same. The RDO confirmed that, in the past, reference checks were considered complete after two documented attempts, regardless of whether references were actually obtained. Several employees had disciplinary actions or were involved in self-reported incidents, but there was no evidence that required pre-employment checks were completed for them. This deficiency was identified during a complaint investigation and had the potential to affect all residents in the facility.