Failure to Complete Required Pre-Employment Screening for Interim DON
Penalty
Summary
Facility administration failed to ensure proper oversight of the hiring process for a registered nurse who was hired as an Interim Director of Nursing. The facility’s Abuse Prohibition policy, last reviewed in 01/2023, required that all prospective employees be screened prior to employment to rule out any history of abuse, neglect, or mistreatment of residents, including criminal background checks, reference checks, credential and license verification, CNA registry checks as applicable, and exclusion checks through government databases such as SAM, OMIG, and OIG. The Administrator’s job description also required assurance that appropriate identification documents are presented prior to employment and that required documentation is filed in the personnel record, as well as responsibility for recruiting and selecting competent personnel. Record review of the RN’s employee file showed that the employment application submitted on 05/04/2023 was incomplete, specifically leaving blank the question regarding prior criminal convictions, and the facility did not ensure all fields were completed. There was no evidence that previous employers were contacted, references were checked, or that the RN’s professional license was verified for enforcement actions. The facility also could not provide evidence that exclusion checks were conducted to determine whether the RN was barred from working in federally funded health care programs. In an interview, the Administrator stated they oversee the hiring process with the Human Resources Director and confirmed that screening procedures are required for all applicants, but acknowledged that the RN’s application should have been checked for completeness and that thorough background checks should have been conducted, and could not provide details of any screening procedures performed for this RN.
