An Office of Inspector General (OIG) exclusion check shows whether a healthcare worker, contractor, or other covered individual is federally excluded from participating in federal healthcare programs. Employers may still need to check state exclusion lists, professional licenses, sanctions, and disciplinary records.
The Fraud and Abuse Control Information System (FACIS) includes several screening levels that may cover federal and state disciplinary, licensing, and sanction records. The right level depends on the role, the organization’s compliance obligations, and the records it needs to identify.
Using FACIS effectively requires employers to make a few decisions. They include:
This guide explains FACIS levels, compliance considerations, pricing, result interpretation, and what to consider when choosing a screening provider.
Important note: The content provided in this guide is for informational purposes only and should not be construed as legal advice.
The FACIS is a commercial healthcare sanctions and exclusions screening database used to identify adverse regulatory information about individuals and organizations.
Organizations may use it to screen candidates, employees, contractors or vendors who work in or support health care settings.
FACIS compiles records from primary sources into a searchable format. Depending on the selected screening level, the search may identify information not included in a standard background check or in a single government database.
Employers can't overlook FACIS because hiring or contracting with an excluded individual can carry serious financial and regulatory consequences. Federal and state authorities generally expect organizations to check and continuously monitor.
FACIS contains adverse-action records for both people and organizations. Individual records can involve physicians, nurses, pharmacists, and other licensed health care professionals. Organization records can involve health care facilities, suppliers, and other business entities.
The records may relate to an exclusion, license action, debarment, or another action taken by a regulatory or oversight body. Since FACIS covers both individuals and organizations, employers may use it to screen people for employment and to evaluate contractors, vendors, or affiliated providers.
Verisys owns and maintains FACIS. It collects records from primary sources and updates the database as new information becomes available.
Employers generally do not access FACIS directly. A background screening provider orders the search and returns the results as part of its screening service. The provider may also help the employer review a potential match and determine appropriate follow-up.
FACIS is not a universal federal screening mandate. The requirement usually comes from the rules, contracts, or accreditation standards that apply to an organization. FACIS can meet those screening obligations when its coverage matches what the organization needs to check.
The OIG maintains the List of Excluded Individuals and Entities (LEIE), and federal health care program participants must take steps to avoid employing or contracting with excluded individuals and entities.
The Centers for Medicare & Medicaid Services (CMS) also establishes requirements for participating providers. Under 42 CFR § 455.436, state Medicaid agencies must screen providers against specified federal databases, including the LEIE, and conduct LEIE and Excluded Parties List System (EPLS, now part of SAM.gov) checks at least once a month.
The System for Award Management (SAM) also contains federal exclusion records relevant to entities that participate in federal contracts, grants, or other awards.
FACIS may help organizations consolidate some of these and other sources, depending on the level and provider. Employers should verify the actual sources included rather than assuming that a FACIS search automatically satisfies every federal or state requirement.
Note: FACIS should not be confused with the federal LEIE. The LEIE is maintained by the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) and is the federal government's source for individuals and entities currently excluded from federal health care programs.
States can impose additional screening requirements on organizations participating in Medicaid and other state health care programs. The requirements can differ by state, including which sources must be checked and how often screening must occur.
Organizations operating in multiple states should review the rules that apply in each jurisdiction. A FACIS search may cover some state sources, though employers should verify the actual sources included before relying on it to meet a specific requirement.
Accrediting organizations can also set standards related to workforce screening and credentialing. The Joint Commission, National Committee for Quality Assurance (NCQA), and Utilization Review Accreditation Commission (URAC) have standards that may address sanctions, exclusions, or professional credentials.
Accreditation requirements vary by organization and program. Employers should identify the specific standard that applies to them and keep records showing how their screening process addresses it.
FACIS has four search levels:
Each FACIS level covers a different range of records. Choose the level that matches the people you screen and the compliance requirements that apply to your organization. A broader search can provide more information, but it may also increase screening costs.
FACIS Level 1 covers federal exclusion and debarment sources. It provides basic federal screening that employers may need to determine whether an individual or entity has been barred from participating in federal health care programs.
Level 1 may be suitable when federal exclusions are the primary concern. Employers with additional state screening requirements may need separate searches to cover those records.
FACIS Level 1M builds on Level 1's federal coverage by adding state Medicaid exclusion and sanction data, state contractor and debarment lists, and related Health Care Fraud Prevention and Enforcement Action Team (HEAT) and Attorney General sources.
Verisys describes Level 1M as the recommended baseline and minimally required compliance search for organizations receiving government healthcare funding. It is designed to meet OIG and CMS minimum screening requirements that a federal-only Level 1 search does not cover.
For most healthcare organizations that bill Medicare or Medicaid, Level 1M is the practical starting point rather than Level 1, particularly when state-level exclusion and sanction data are relevant to their compliance program.
FACIS Level 2 includes the federal coverage in Level 1 and adds state-level board and other source information for one specified state. The additional coverage can give employers more information about adverse actions than a federal-only search.
It makes sense for organizations that need broader screening without going as far into state licensing and disciplinary records as Level 3.
FACIS Level 3 provides the broadest search of the three levels. It includes federal sources along with state licensing and disciplinary records, giving employers more information about actions involving licensed professionals.
Level 3 may be appropriate for organizations where professional licensing and state-level discipline are important to the screening decision. The need for this level depends on the roles being screened and the organization's specific compliance requirements.
Below is a breakdown of each level, followed by a decision framework:
Choosing the right FACIS level starts with understanding what your organization needs to screen for:
A FACIS report shows the records returned by the sources included in the search level ordered. The information can help employers determine whether an individual or organization has a relevant exclusion, sanction, or disciplinary record.
A FACIS report identifies whether an individual or organization appears on federal exclusion and debarment sources. These records indicate that a party has been barred from participating in federal health care programs or federal contracting, and they represent the most clear-cut disqualifiers most employers will encounter.
Depending on the search level, a FACIS report can reveal actions taken by state licensing boards. These include suspensions, revocations, probation, reprimands, and other disciplinary measures against a professional's license. Such records provide valuable context about a candidate's professional history that a federal-only check would miss entirely.
Some of the sources FACIS draws on, including OIG exclusions, HEAT actions, and state Attorney General fraud sources, reflect conduct involving health care fraud, abuse, or other regulatory violations. FACIS reports the resulting exclusion, debarment, or sanction from those sources.
These records can provide important information about enforcement actions, but FACIS is not a criminal history search. It complements, rather than replaces, a criminal background check when an organization needs to assess criminal convictions or other criminal history.
The OIG exclusion list and SAM.gov are valuable, but each has its own limitations. Understanding where they end and where FACIS begins is essential to designing a program that neither over-relies on a single source nor leaves gaps.
The practical rule: Start with the records your organization must check, then determine whether FACIS covers those sources or whether separate OIG, SAM, state or licensing board searches are still needed.
Running a FACIS search is only one part of a screening program. Employers also need to decide when to screen, who falls within the program, how to handle results, and what records to retain.
A point-in-time FACIS search shows what the covered sources report when the search is conducted. A person's status can change later, so a clear result at hiring does not establish that status indefinitely.
Continuous monitoring checks for new records after the initial search and can alert an employer when a relevant change appears. Whether ongoing monitoring is required depends on the organization's regulatory and contractual obligations. Employers should also set a clear process for reviewing and documenting alerts.
Employers can include FACIS with other medical background checks during pre-employment screening. Employers should determine when the search occurs in their hiring process and ensure the timing aligns with applicable law and company policy.
For roles where exclusion status affects eligibility to work or participate in a program, employers should resolve relevant findings before allowing the individual to perform the affected work.
Contractors, vendors, staffing-agency workers, and affiliated providers can also be subject to exclusion or sanction requirements, depending on their role and the organization's obligations.
Since FACIS can include records involving both individuals and entities, employers can use it to evaluate parties outside their direct workforce. The organization should define the population to be screened based on its specific requirements.
Employers should verify the individual’s identity and review the underlying record before treating a FACIS result as a confirmed finding.
A name match alone is not enough to confirm that a FACIS record belongs to a candidate. Compare additional identifiers available in the report, such as date of birth, address, professional license information, or other identifying details.
If the identifiers do not establish that the record belongs to the candidate, treat it as a potential match and investigate further. Do not reject someone solely because their name resembles a person on a sanctions or exclusion record.
Use a consistent review process:
A confirmed exclusion can have different consequences from a licensing action or an older disciplinary record. The response should depend on the actual finding and the requirements that apply to the organization.
If a FACIS report is obtained from a consumer reporting agency (CRA) and used for employment purposes, the Fair Credit Reporting Act (FCRA) requirements may apply.
Before taking adverse action based on the report, an employer generally must provide the individual with:
If the employer proceeds with adverse action, additional notice requirements apply. Employers should follow the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) requirements and obtain legal advice for their specific process.
Legal review is especially useful when:
Verify the match before treating a FACIS record as a disqualifying finding.
The background check provider determines which FACIS sources you can access, how potential matches are reviewed, and how results reach your team. Compare providers on coverage, accuracy controls, compliance support, and integration before choosing one.
Start by evaluating each vendor on the following requirements:
Which FACIS levels do they offer, and how do they help you select the right one?
What quality-control process do they apply to potential matches?
Do they support continuous monitoring in addition to point-in-time checks?
How do they handle the FCRA adverse action workflow?
How accessible is their support team when you have a time-sensitive question?
Turnaround time matters when FACIS is part of pre-employment screening. Ask how quickly standard searches are returned and how potential matches affect that timeline.
Also, check how results fit into your existing systems. AccuSourceHR provides FACIS screening through its SourceDirect™ platform, with a RESTful application programming interface (API) and integrations with applicant tracking system (ATS) and human capital management (HCM) platforms.
Industry credentials can provide useful information when comparing screening providers. AccuSourceHR is a founding member of the Professional Background Screening Association (PBSA) and has undergone a System and Organization Controls (SOC) 2 Type II audit.
Employers should verify what each credential covers and whether it applies to the services they are purchasing. Accreditation or a security audit does not, by itself, establish that a provider's FACIS search meets a particular regulatory requirement.
AccuSourceHR combines FACIS screening with U.S.-based client support and in-house compliance expertise. Its customer success team includes professionals with Professional Background Screening Association (PBSA) and Fair Credit Reporting Act (FCRA) certifications who can assist with screening questions and potential results.
AccuSourceHR also has in-house counsel supporting its compliance function, which can be useful when a FACIS result requires closer review or when an employer needs help understanding the screening process.
For employers comparing FACIS providers, these service and compliance resources are worth evaluating alongside search coverage, technology, turnaround times, and reporting. The goal is to have a provider that can support the screening process when a result requires more attention than simply returning a report.
Most employers should run FACIS at hire and then on an ongoing basis, because exclusions, sanctions, and disciplinary actions can appear after onboarding. A point-in-time search helps at the hiring stage, but recurring monitoring is the safer approach for regulated healthcare settings.
Individuals usually cannot log into FACIS directly because it is a business screening database, not a public self-service system. They can, however, review many of the underlying public sanction or exclusion sources themselves, and they may be able to obtain a copy of any consumer report that was used in an employment screening decision.
FACIS is a sanctions and exclusions search for healthcare compliance, while a standard criminal background check looks for arrests, charges, and convictions. FACIS focuses on whether a person or entity has been excluded, debarred, or disciplined by government or licensing authorities, which is a different risk than criminal history.
A screening program should leave a clear record of what was checked and what happened when a result required follow-up. Employers may want to retain:
Retention requirements can vary, so organizations should follow their applicable laws, contracts, and internal policies.
Any organization touching federal or state health care dollars carries exposure, but certain settings face heightened risk. Hospitals and health systems, long-term care and skilled nursing facilities, home health and hospice agencies, pharmacies, managed care organizations, and staffing firms that place clinical personnel all tend to sit within the highest-scrutiny categories.
These settings typically involve direct patient care, federal reimbursement, and large or fluid workforces. That combination makes rigorous, ongoing sanction screening essential.