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How Should We Run Background Checks on Our Staff?

Clearance and Background Checks is an addressable standard under HIPAA’s Security Rule, which means that your organization may authorize a background check for any new employee or existing workforce member who engages in activities that cause the Security Official to question clearances. As part of your compliance activities, you already determined the risks your workforce presents to your practice, and you assigned one person to own/manage this risk

As part of your clearance procedures, determine which of the following you will do:

» Require a written application for employment.
» Require written proof of citizenship or resident alien status.
» Confirm prior employment history.
» Request professional/personal references and contact those references.
» Confirm educational history and practicing credentials.
» Verify licenses.
» Verify candidate’s compliance history with any regulatory or medical requirements relevant to employment.
» Conduct a criminal background check using a consulting service.
» Confirm application statements, as appropriate.
» Require up-to-date written documentation for Federal and state tax withholding and Social Security Numbers.

Document all assigned security clearances, such as passwords, building entrance pass, and office key to each workforce member, as appropriate. Expect workforce members to acknowledge in writing receipt of clearances and immediately inform the Security Official of any change in job responsibilities.

Authorize your Security Official to cancel immediately any clearances when notified that a member of the workforce’s employment has terminated for any reason.

Carolyn Hartley, Healthcare Authority & EHR Consultant

Filed Under: Health IT and HITECH 
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