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What are the background check requirements for governing board members that comply with HRSA and CMS regulations?
Thanks for your question! Based on the 2019 HRSA Governance Manual released by NACHC, it is a good practice for the board to have a policy in place that addresses background checks for board members. These can be conducted prior to inviting an individual to formally join the board and periodically throughout a member’s service. As part of this policy, it is important a board require checking members against the Office of the Inspector General’s exclusion list – which lists individuals and entities excluded from Federally funded health care programs for various reasons, such as a conviction for Medicaid or Medicare fraud – so as not to put the center’s federal award at risk. Some organizations also opt to conduct a criminal background check. It is important to seek permission of potential and current board members prior to undertaking such checks. It is also suggested that a health center consult with qualified legal counsel regarding any requirements or restrictions on this process in the state in which the health center is based.
For more information, please refer to the HRSA Governance Manual released in 2019, which can be found HERE.