Incomplete Background Check for RN-E: The facility did not fully implement its abuse, neglect, and exploitation screening policy for an RN. Although part of the background check was completed before hire, the DOJ and Governmental Findings reports were dated much later, and the agency that supplied the RN said the file had been deleted. The NHA stated the facility should have completed all pre-employment screening before employment and retained copies of the screening documents.
An LPN was cited after the facility failed to complete and document required BID, IBIS, and DOJ background checks upon hire and every 4 years thereafter, as required by its abuse, neglect, and exploitation policy. During survey review, the NHA confirmed there was no documentation of the required checks and stated they should have been completed on the required schedule.
The facility failed to follow its abuse prevention policy by not completing required criminal background checks before hiring 4 of 8 employees reviewed. Records showed that an RN, a life enrichment staff member, and 2 CNAs had DOJ/IBIS and related background checks completed after hire, and one staff member also had an out-of-state check completed late. The NHA stated background checks had not been done for new hires before the NHA began working at the facility and agreed this was a problem.
A facility failed to follow its abuse prevention and employee screening policy for a newly hired cook. The cook’s BID showed prior residence in Iowa and [NAME] Virginia, but the required background checks for those states were not in the file. During interview, the NHA confirmed the checks had been missed and should have been completed.
Failure to complete required background check for CNA. The facility did not ensure its abuse, neglect, and exploitation policy was followed for a CNA whose BID form showed prior residence outside WI within the previous 3 years. Record review and staff interview showed the required out-of-state background check was not completed before hire, and the GSC and NHA both stated it should have been done prior to employment.
A facility failed to follow its abuse-prevention background check process for an RN whose BID showed a recent military discharge. The RN’s file did not include the required DD214, and the NHA confirmed the document was missing and had only just been requested.
Failure to Complete Required Pre-Employment Background Screening: The facility did not follow its abuse policy requiring pre-employment background screening for all employees. Review of employee records found that one employee disclosed prior residence in Minnesota within the last 3 years, but no out-of-state background information disclosure was completed before the employee began working. The NHA confirmed the review had not been done and said the facility was completing it.
Failure to complete required employee background checks. The facility did not follow its screening policies for abuse prevention when it failed to complete the required WI Caregiver Background Check for a social service director and a receptionist, and did not obtain an IL or national background check for a contracted PT who had lived outside WI within the past 3 years. Interviews showed the BOM treated clinical and non-clinical staff differently, while the NHA stated all staff should have the caregiver background check completed and out-of-state residents should have the appropriate state-specific or national check.
The facility did not follow its abuse, neglect, and exploitation prevention policy requiring complete pre-employment screening when it hired an LPN without obtaining the required Department of Justice and Governmental Findings background reports. Record review later showed that these checks were only completed long after the LPN’s hire date, and interviews with the HR director and NHA confirmed that the mandated background documentation was missing from the personnel file prior to employment.
Missing Employee Background Check Documentation: The facility did not follow its abuse screening policy for an employee whose IBIS background check could not be located in the file. The policy required screening prospective employees for a history of abuse, neglect, exploitation, or mistreatment and obtaining a criminal background check through the state system, but the NHA and Staff Development Director reported the IBIS form for the housekeeper hired around that time was missing.
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Citations used to create this checklist
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