You Asked: How many reference checks are required when hiring nursing home staff? Is a facility compliant if it attempts to obtain references from prior employers but receives no response?
We Answered: Neither federal nor Ohio nursing home regulations specify a required number of reference checks that must be completed before hiring an employee. Under F606 of the State Operations Manual Appendix PP, facilities must be thorough in their investigations of the histories of prospective staff. In addition to inquiry of the State nurse aide registry or licensing authorities, the facility should check information from previous and/or current employers and make reasonable efforts to uncover information about any past criminal prosecutions.
The Ohio Revised Code 3721.121 also emphasizes an employer's good-faith efforts when screening and hiring individuals who provide direct care to older adults.
According to the Ohio Department of Health (ODH), surveyors would expect facilities to make reasonable efforts to obtain information from prior employers and to follow their abuse prevention policies regarding employee screening. If a facility attempts to contact prior employers and documents those efforts, the lack of a response from an employer would not, by itself, indicate noncompliance. While conducting only one reference check is not specifically prohibited, facilities should ensure their hiring practices are consistent with their own policies and demonstrate reasonable efforts to investigate an applicant's employment history.