Volunteer Screening: A Guide To Background Checks in Healthcare

Most organizations assume that sanction screening requirements only apply to employees, vendors, and other professional staff. However, volunteer background checks within healthcare must cover the same exclusion lists, as they may still be considered a risk to patient safety. 

This article explores how volunteer screening works and why it matters – along with best practices to improve your processes and elevate your compliance program. 

What Are Volunteer Background Checks? 

Volunteer background checks assess whether a volunteer can safely fill a role. From employment history and professional exclusion lists to criminal records, the process evaluates the individual’s previous behavior – and flags any potential risks or reason to avoid working with them.  

Why Volunteer Screenings Are Important for Healthcare Organizations 

Such screening is critical in hospitals, nursing facilities, and other healthcare organizations where vulnerable patients are served. Not only are there several industry-specific exclusion lists to consider, but there are also heightened risks associated with allowing a volunteer within the organization. From data security to patient safety, leaders must have robust processes to protect their patients, employees, and reputation. 

Organizations should screen volunteers, regardless of whether the volunteers’ duties and responsibilities extend directly or indirectly to patient care. Although volunteers are not paid through federal health care programs, they may have worked in the past or currently work in another position that requires submission of claims to federal health care programs.  

If the volunteer is found to be on a federal or state exclusion list, the excluded individual’s continued involvement directly or indirectly in the health care facility may put the facility’s patients, and its operations, at risk. Therefore, organizations should include volunteers in their sanctions and exclusions screening to cover everyone who is associated with the organization in any way. 

The OIG’s View of Screening Healthcare Volunteers 

The Department of Health and Human Services Office of Inspector General (OIG) states that any party providing an item or service that is either directly or indirectly paid by a federal health care program should be screened against the List of Excluded Individuals and Entities (LEIE). As such, those arguing against screening volunteers may claim that because volunteers are not included in making requests to the federal government for payments, nor getting paid by the facility, they do not need to be screened.

However, in their recent Special Advisory Bulletin[1], the OIG sought to clarify sanction screening against the LEIE in terms of scope. The OIG noted that sanction screening requirements apply even if the excluded person changes from one health care profession to another while excluded, regardless of whether the person is an employee, a contractor, or a volunteer or has any other relationship with the provider. For example, an individual could be excluded as a paid employee, but he or she may work as an unpaid volunteer at the same facility or in another part of the health care industry. Similarly, an excluded contractor could change professions to become a paid employee, but he or she is still on the LEIE as an excluded entity.

Additionally, the OIG stated that prohibitions under exclusion go beyond direct patient care and emphasized that excluded persons are prohibited from providing administrative and management services payable by federal health care programs. These kinds of services can include serving as an executive or in a leadership role (e.g., CEO, CFO, general counsel, physician practice office manager, etc.) for a provider that provides items and services payable by federal health care programs. The OIG also explained that the scope of prohibited administrative and management services extends to health information technology service support, strategic planning, billing and accounting, staff training and human resources, unless any of these roles are wholly unrelated to federal health care programs. Anyone employed in these roles could also be serving in a volunteer capacity elsewhere. Therefore, screening individuals on a facility’s volunteer list helps organizations discover whether their volunteers are excluded under a different profession or capacity in any other sector of health care.

What Are the Key Volunteer Background Check Requirements?  

Before undertaking a background check for any healthcare volunteer, two steps must be taken: 

• Consent and Disclosure: The volunteer must be made aware of the check and provide written consent for the background check, as per the Fair Credit Reporting Act (FCRA). There may also be state laws that make such disclosures mandatory. 
• Identify Verification: The volunteer’s identify must be verified using government-issued identification. This would typically involve obtaining their Social Security number. 

Once you have these in place, there are several  

How to Run Background Checks on Healthcare Volunteers 

Volunteer background checks typically involve four primary assessments: 

• Criminal Checks: Check local, state, and national databases for information about criminal offences. This will usually involve working with a third-party company that can aggregate data from multiple sources to enable fast and accurate checks. 
• Exclusion Lists: Search all relevant exclusion lists to ensure the volunteer is not legally barred from working within healthcare. Exclusion lists often contain instances of malpractice that have not led to criminal convictions, meaning this is an important additional step and distinct from basic criminal background checks. 
• Employment History: Evaluate and verify the volunteer’s employment history to ensure they have not engaged in dangerous or unethical behavior in the past. Most organizations will expect 1-2 written references. 
• Social Media: Find and assess the volunteer’s social media profiles for potentially incriminating behavior. Healthcare organizations should remember that HIPAA extends to social media usage; volunteers who post frequently about their work may present a data privacy risk. 

Compliance teams must document each step taken and evaluate the evidence they accumulate before making a decision about working with the volunteer. But many organizations will struggle to undertake all these processes in a timely and efficient manner – which is where Compliance Resource Center comes in. 

Improve Your Volunteer Background Checks with Automated Sanction Screening 

Healthcare volunteers can feature on numerous exclusion lists – from the OIG LEIE and SAM to TRICARE and OFAC. But manually running and verifying multiple scans for every volunteer adds to your compliance team’s already heavy workload. Many organizations end up missing key exclusion lists, which leaves them at risk of non-compliance.  

Compliance Resource Center offers automation sanction screening software to make the screening process fast, simple, and scalable. Our platform uses data from all relevant exclusion lists to quickly and accurately evaluate whether an individual can be safely introduced to your organization. 

Interested in learning more about sanction screening? Contact Shelby Cole at [email protected]. 

[1] U.S. Department of Health and Human Services Office of Inspector General. “Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs.” May 8, 2013.

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