Failure to Complete and Document Required Pre-Employment Background Checks
Penalty
Summary
The facility failed to implement and follow its written policies and procedures to prohibit and prevent abuse, neglect, exploitation, and misappropriation of resident property by not ensuring required pre-employment screening was completed and documented for one nurse aide (NA-A). Record review of NA-A’s employee file showed a hire date of 01/01/2026 with no evidence that an Employee Misconduct Registry (EMR), Nurse Aide Registry (NAR), or criminal history check had been completed prior to hire or before NA-A began working on the floor on 01/02/2026. The facility’s Abuse, Neglect, Exploitation and Misappropriation Prevention Program policy, dated April 2021, required the facility to conduct employee background checks and not knowingly employ individuals with findings or disciplinary actions related to abuse, neglect, exploitation, mistreatment, or misappropriation. During interviews, the Administrator (ADMN) confirmed that NA-A was hired and began working with residents without documented EMR/NAR and criminal history checks in the file and stated he could not locate these records, although he believed they had been done. The Director of Nursing (DON) stated that employees should be screened for criminal history and EMR/NAR checks before being allowed access to residents and acknowledged she did not know why these checks were not completed for NA-A before she started working. The DON also stated she did not know who monitored to ensure the mandatory checks were done. The ADMN further stated that Corporate HR was responsible for monitoring that pre-employment checks were performed but he did not know how often this monitoring occurred, and he acknowledged that the absence of these checks could allow an unemployable person to work with residents.
