Learn about healthcare background check requirements by state. Discover state-mandated criminal background check requirements for healthcare licensure.
Healthcare background check requirements can differ greatly by state because each state medical licensing board establishes its own screening standards and disqualifying criteria. The Federation of State Medical Boards (FSMB) reports that upwards of 50 medical boards (13 states have more than one) maintain background check requirements for continued licensure. This article breaks down some of those obligations to make it easier for healthcare providers to tackle.
Fingerprint background checks are a common method of screening for criminal history in healthcare.
Effective multi-location screening combines high-level company goals with location-specific compliance considerations.
Contracted professionals may need to be screened to state standards, like full-time employees.
Nearly every state and U.S. territory requires fingerprint background checks for healthcare workers. Most state medical boards include this measure for healthcare workers in hospitals, long-term care facilities, and licensed caregiving environments. Three notable exceptions are Massachusetts, New York, and the Northern Mariana Islands:
Massachusetts only mandates fingerprint background checks for Executive Office of Health and Human Services (EOHHS) and Department of Developmental Services (DDS) staff and those seeking a multistate license.
New York allows medical professionals to submit an attestation of good moral character in lieu of a formal background check, unless mandated by the Board.
The Northern Mariana Islands’ Health Care Professions Licensing Board (HCPLB) only requires fingerprint criminal history checks when requested by the Board themselves.
Although most states mandate these checks for healthcare staff, relying solely on fingerprint-based screening is limiting. The Professional Background Screening Association (PBSA) reports significant gaps due to their nature as static databases that can become outdated quickly. Employers are encouraged to combine this method with primary source searches when screening candidates.
Healthcare organizations may be required to rescreen employees with specific sources periodically, depending on legal requirements or organization policies. Common recheck sources include the following.
The U.S. Department of Health and Human Services’ (DHHS) Office of Inspector General (OIG) maintains a list of individuals and entities excluded from participating in federally funded healthcare programs. Medical providers are encouraged to monitor these, as they may be subject to exclusion from federal healthcare programs, severe monetary fines, or criminal charges for employing excluded individuals.
State medical board standards and internal risk management policies often require repeated background checks for healthcare workers to maintain licensure or employment. Some states, like Utah, also require applicants to subscribe to the FBI’s Rap Back system, which monitors criminal history events. This system allows healthcare employers to monitor changes in their staff’s criminal history on a national level, but as a fingerprint-based repository, it may not be up to date or comprehensive.
Some states require abuse registry checks for healthcare employees to prevent individuals with histories of abuse or neglect from working with vulnerable patients. On top of the harm these exploitations cause, abusive behavior damages an organization’s standing with its community.
For more about the importance of abuse registry checks, read Protecting Vulnerable Populations with Abuse Registry Search >
Healthcare systems often standardize screening across multiple states through company-wide policies and jurisdiction-specific compliance workflows. Organizational codes of conduct may broadly stipulate employees “complete mandatory and required elements of employment” without specifying exact requirements. The organization then takes a state, county, or municipality’s background screening regulations into account when creating and administering policy for their location(s) within the area.
Healthcare employers should consider screening traveling medical professionals in a similar fashion to local staff. With the same access to sensitive areas, equipment, and patients that full-time employees have, healthcare providers need to know that incoming doctors, nurses, and specialists are reliable and don’t pose a risk.
To read more considerations about contracted professionals, check out Busting Common Contractor Screening Myths: Truths That Every Employer Should Know >
If state healthcare screening laws conflict with company policy, the state’s regulations supersede the employer’s. For example, an employer with locations in California and other states must still adhere to Ban the Box laws in the Golden State even if the company policy requests criminal history at the time of the interview. Employers that attempt to circumvent state screening laws may incur penalties like compensatory and punitive damages and legal fees.