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Employment Tracking and Verification in Illinois
Employment Tracking and Verification in Illinois
As part of the NBCP program in Illinois, providers/facilities are required to record employment information and, at least annually, verify their employee rosters. The maintenance of employee rosters allows providers/facilities to receive notifications if a fitness determination changes for one of their employees. It also meets the Illinois State Police (ISP) Criminal Justice Information System (CJIS) requirement for enrolling and maintaining employees in the State rap back program. Another benefit this data provides is that it allows the Illinois Department of Public Health to track statewide long-term care employment trends.
The National Background Check Program requires facilities/providers to conduct background checks on all applicants covered under the program. It also encourages States to reduce duplicative fingerprinting through rap back – the capability to update direct access employee records alert employers if the individual is later convicted of a disqualifying crime. One of the challenges faced in meeting these two requirements is the need to maintain accurate and up-to-date rosters of employees in order to notify the correct facilities/providers. An additional advantage to States in having accurate rosters is that they can be used by State surveyors to ensure that providers/facilities have conducted background checks on every employee and that these employees are still eligible to work based on State and Federal requirements. Grantee states vary widely in their policies for requiring employee information from providers on an ongoing basis.
The Illinois Health Care Worker Background Check Act is the background check program authorization. The Act requires providers/facilities to record hire and termination dates for each direct access employee in the Health Care Worker Registry (HCWR) - the State’s web-based applicant background check system maintained by the Illinois Department of Public Health (IDPH). Facilities/providers are also required to verify their employee rosters at least once a year.
Employment tracking is a part of Illinois’s standard hiring process for NBCP-covered employees. Providers enter each applicant’s information in the HCWR and generate a request for the applicant to be fingerprinted. Once the HCWR gets confirmation that the applicant has submitted fingerprints to ISP, the provider may hire the applicant in a conditional status. The provider is required to record the conditional hire in the HCWR, which automatically records the conditional hire date. When the HCWR receives the applicant’s criminal history, IDPH staff makes a fitness determination for that applicant in HCWR. After the fitness determination is made and the provider/facility is notified. The provider/facility may then permanently hire the applicant if qualified, or it must terminate the applicant if he or she is found ineligible. The HCWR records the date of this hire or termination. Providers/facilities must also update the HCWR anytime an employee is terminated or leaves employment. The HCWR is thereby able to generate an accurate roster of current employees for each facility/provider in the State.
Employment verification is also required under the Act. To meet this requirement, each provider/facility must at least annually review its employee roster in the HCWR database, and update as needed. Periodically, the HCWR sends an automatically generated email to providers asking that they log in and verify their employee rosters in the system.
Illinois is one of the first States to implement rap back for long-term care workers, and the process functions well in part because of Illinois’s mandatory employment tracking system. When rap back information is received by the ISP, it knows immediately if IDPH asked to be notified if background check and rap back monitoring on that employee produced new information about their criminal history. They forward the new information to IDPH which then makes a new fitness determination on that employee. If the employee’s eligibility status changes, the IDPH informs the correct provider/facility and ensure that the employee’s employment is terminated if necessary. Without accurate employment tracking, the rap back notification process instead would be a multistep process: First, an inquiry from ISP would be required to determine if IDPH is still interested in information about the employee; IDPH would then need to query providers to see if the employee was still employed; if a positive response was received, IDPH would let ISP know that the new information was needed; ISP would then need to transmit the information to IDPH for eligibility review.
Illinois’s employment tracking process also provides IDPH an access to statewide employment information on long-term care facilities/provider employment trends. For example, IDPH is able to identify the number of nurse aides employed at any nursing home in the State. IDPH is able to tract this information over time, and use this data to make changes in HCWR policy, if necessary.
Illinois’s practice provides a model for other grantee States. Interested States should be aware that providers/facilities typically need an incentive or requirement to motivate them to keep accurate employee rosters. Also, employment tracking works best when the providers/facilities are required not only to record hire and termination dates but to verify their rosters at periodic intervals.