Failure to Complete Pre-Employment Background Checks Prior to Hire
Penalty
Summary
The facility failed to implement its abuse and neglect prevention policies for two out of eleven personnel records reviewed. Specifically, the facility's policies required that all new offers of employment be contingent upon the successful completion of background checks, including checks against the Kentucky Adult Caregiver Misconduct Registry, OIG Exclusion List, and other relevant registries. However, documentation revealed that one Patient Care Assistant (PCA) was hired and began employment seven days before the completion of the required misconduct registry check, and another PCA started work three days before both the misconduct registry and OIG Exclusion List checks were completed. Interviews with facility leadership, including the Executive Director of Human Resources, Unit Manager, acting Director of Nursing, and Administrator, confirmed that the established process was to complete all background checks prior to allowing new employees to begin work. Despite this, the records showed that these procedures were not followed in the two identified cases, resulting in the potential for residents to be exposed to individuals who had not been fully vetted according to facility policy.