Expanding Smart Hiring Beyond State Fingerprinting

Healthcare organizations carry some of the highest stakes in talent acquisition. Every hire, from RNs and CNAs to allied health technologists, physicians, and behavioral health specialists, has a direct impact on patient safety, regulatory compliance, and organizational risk. While the state fingerprint-based checks are a valuable step in the hiring screening process, they provide only one layer of screening and rely on a single source of biometric data. In healthcare, an industry where identity-based hiring fraud, license falsification, and cross-state mobility have all sharply increased,1 relying solely on fingerprint-based Criminal History Record Information (CHRI) leaves information gaps. A layered approach using many data sources can provide thorough screening for healthcare hiring.

What fingerprint-based record checks do cover?

State fingerprint repositories do not contain and are different from FBI information. They contain the records that the state collects from lower county jails and courts, which they then report up to the FBI.

State fingerprinting typically includes:

• Arrests and criminal submissions reported to the FBI
  The IAFIS compiles fingerprints and arrest information submitted by state and local law enforcement agencies. When the agency reports both fingerprints and the related disposition, the record is included.
• Federal crimes
  Federal arrests and convictions, such as fraud and narcotics, prosecuted by the federal court system, are generally included.

State fingerprint-based criminal history checks provide a centralized starting point for screening healthcare candidates, especially for positions that require trust and public safety. But a layered approach is necessary to be as thorough as possible.

State fingerprint-based criminal background checks provide only one layer of screening

Healthcare hiring requires more than a criminal history search, as fingerprint-based checks do not cover:

• State Board of Nursing and Medical Board disciplinary actions
• Residency status or employment history
• Civil malpractice judgments
• Abuse registry checks (e.g., OIG, SAM, state Medicaid exclusion lists)
• County-level misdemeanors that were never fingerprinted
• Non-finger-printable offenses such as DUIs, simple assault, or certain theft categories

In practice, for example, a nurse could be disciplined in one state, practice in another, and pass a fingerprint-based criminal record check with no red flags appearing.

Why thorough screening matters more now than ever in healthcare

Shifting market dynamics are increasing the complexity of healthcare hiring and raising

the stakes for thorough, consistent candidate screening. For example:

• Fraud and impostors are on the rise
  First Advantage, staffing agencies, and health systems across the U.S. report sharp increases in impostor applicants using forged credentials, modified IDs, or falsified licenses. This added layer of complexity is important to note in this context because a fingerprint capture alone cannot confirm whether the person presenting that ID is the same person associated with the fingerprinted record.
• Clinicians are highly mobile
  RNs, CNAs, and allied health professionals often move across states or work multiple travel assignments. Fingerprint-based criminal history will not catch licensure actions in other states or state-level abuse findings.
• Remote and global hiring increases the risk
  Many telehealth, teleradiology, and virtual behavioral health workers live and work outside the state where the employer is based. There are gaps when relying only on IAFIS fingerprint-based checks, as they do not include international criminal history, global sanctions or foreign identity documents.

Hiring fundamentals to look for when screening

Healthcare organizations require more thorough checks because patient-facing roles are prone to risk and serve vulnerable populations. Best practice healthcare hiring fundamentals should include answers to questions such as:

• Is this the clinician they claim to be?
• Are their licenses valid and free of disciplinary action?
• Have they been excluded from Medicare/Medicaid programs?
• Are there county-level convictions that never reached the FBI?
• Did they work under a different name previously?
• Is there an international criminal history, sanction, or identity risk?

Further, all of these questions should be answered in relation to the specific role and responsibilities being filled. These need to be mapped to the screening necessary to confirm that the person hired has the qualifications appropriate for the position.

How healthcare employers can build a stronger, layered screening program

Fingerprint-based CHRI or national databases can be part of a broader strategy and a valuable source of information when used as part of a layered screening approach. Best practice suggestions for healthcare organizations include a multi-tiered screening model that includes:

• Verifying identity at the start
  Use modern, biometric document-authentication tools to confirm identity before screening begins. This helps catch impostors, stolen identities, and manipulated documents.
• County-level criminal searches
  Go directly to the source, as this is the gold standard for screening. County courts hold the most up-to-date information on crimes committed in places where people live and frequent.
• Statewide checks
  Combine local court searches with statewide repositories to close jurisdictional gaps. Statewide databases aggregate county data but may also include additional information relevant to the candidate.
• Federal checks
  The federal courts are a fully separate court system and include federal-level crimes such as kidnapping, terrorism, money laundering, or criminal activities that cross borders – activities that would not be reported at the state or county level.
• Healthcare-specific registries
  These are essential for clinical hiring:
  • OIG and SAM exclusion lists
  • State abuse and neglect registries
  • Professional licensing boards
  • National Practitioner Data Bank (NPDB)
• Credentialing and license verification
  Confirm that licenses are active, valid, and unencumbered, and continuously monitor them.
• Drug screening and occupational health screening
  Assess clinicians so they are fit for duty and meet regulatory requirements.
• International checks for global or remote roles
  For clinicians who live or previously lived abroad, conduct:
  • International criminal history
  • Global sanctions and watchlists
  • Identity document verification
  • Local employment reference checks
• Ongoing monitoring
  Continuous monitoring for license updates, sanctions, and convictions helps organizations respond to emerging risks early.

The bottom line

Fingerprint-based criminal record checks are an important tool in the process of screening healthcare candidates. They were never designed to be the only source of truth in healthcare hiring. By building a layered screening program and addressing the specific roles and responsibilities they are required to fulfill, healthcare organizations can better mitigate risks and fraud and hire with greater confidence in an increasingly complex and global workforce.

Frequently Asked Questions