Failure to Complete and Document Pre-Employment Screening for CNA
Penalty
Summary
The deficiency involves the facility’s failure to implement its Abuse, Neglect, Exploitation, and Misappropriation Prevention Program and Hiring policies by not conducting and documenting required pre-employment screening for a certified nursing assistant (CNA 1). Review of CNA 1’s personnel file, including the Personnel Action Form, showed prior employment at another skilled nursing facility. The Pre-Employment Reference Check List (PERCL) for CNA 1 contained only a name of a former employee as the first reference, with no title documented, and a second reference listing only the prior facility’s company name and the current Director of Staff Development’s (DSD) name, without an interview date, employment verification dates, or other required information. The DSD confirmed CNA 1’s date of hire and that the PERCL lacked complete documentation. During interviews, the DON stated that pre-employment reference checks are part of ensuring safety, confirming qualifications, and determining whether an applicant has any history of resident abuse, and clarified that RNA or CNA staff are not permitted to provide professional employment references or verify employment history. The DON further stated that the reference from the restorative nursing assistant appeared to be a personal reference and that the former DSD had not completed CNA 1’s PERCL prior to hire. In a separate interview, the Administrator acknowledged that the purpose of pre-employment checks is to identify any negative history and that it was difficult to determine whether such checks had been completed for CNA 1. Review of the facility’s Abuse, Neglect, Exploitation, and Misappropriation Prevention Program policy showed a requirement to conduct employee background checks and not knowingly employ individuals with disciplinary actions related to abuse or misappropriation, and the Hiring policy allowed for background investigations for applicants and current employees, which were not properly carried out or documented for CNA 1.
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