This policy is listed for reference only and should be reviewed with your lawyer before implementing them into daily practice. We are not lawyers and are not providing any legal advice. View our legal disclaimer.

Workforce Security: Clearance Policy

Reference: 45 CFR 164.308(a)(3)(ii)(A)
Last Updated: May 19, 2024


The purpose of this policy is to standardize the hiring process of new employees.


All employees will go thru a screening procedure prior to hiring. Employees must also agree that as condition for employment a background investigations, drug screenings and researches thru other sources such as the Office of the Inspector General (OIG) list of excluded individuals may be conducted.

    • The following steps will be conducted to verify prospective employees against the OIG database:
      1. Compliance Officer or designated representative must collect and verify the name of the employee to be screened. Verification must be confirmed against a Government certified document such as driver’s license or passport.
      2. Compliance Officer or designated representative will sign on OIG web’s site:
      3. Type employee’s name and/or aliases on the proper blocks.
      4. Print a copy of the results and file under the individual’s employment folder/application.
      5. Candidates that have been excluded by the OIG will not be given an employment opportunity.
    • Personnel check:
      • Call previous employers and ask basic questions regarding responsibility and reliability of prospective employee.
        • Would you hire back this person?
        • What are this person’s greatest strengths/weaknesses?
      • Call references and find out relationship and objectiveness of comments prior to asking further questions. Consider questions regarding employee’s ability to perform desired tasks.
        • Would you hire this person?
        • What are this person’s greatest strengths/weaknesses?
      • Contact previous schools and instructors.
        • Verify completion as indicated in employment application.
        • Ask instructors about reliability, honesty and responsibility of candidate.
      • Contact licensing Agency and verify validity of licenses (if applicable).

Depending on the responsibilities of the position a credit and criminal history review may be conducted by the Compliance Officer or designated representative.

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