All,

The Feds released the attached Special Advisory Bulletin around the time of the overhaul of HIPAA regulations.  It's a good reminder to check OIG's exclusion list before as part of the process of doing background checks.

Diane Evans

Diane Evans
Publisher, MyHIPAA Guide
Website: MyHIPAAGuide.com
Residential Services Website: hipaa.opra.org
Cell: 330-990-1470 


On Tue, Dec 11, 2018 at 9:06 AM Lynne Urbanski <lynneu@blossom-hill.org> wrote:

It is our policy to wait 90-days before allowing anyone to take the med administration classes.  This way everything is back and we have a great idea how trustworthy this staff member is.  We have found out in the past that BCI/FBI does not necessarily tell the whole story.  Work ethic, attendance, attitude etc are all important factors in trusting someone to pass medication.

 

Lynne Urbanski

CEO

Blossom Hill, Inc.

 

From: opra_members@opra.simplelists.com [mailto:opra_members@opra.simplelists.com] On Behalf Of jlelson@prodigy.net
Sent: Tuesday, December 11, 2018 8:39 AM
To: soaroffice@yahoo.com; Dennis Grant
Cc: Anita Allen; opra_members@opra.simplelists.com
Subject: Re: Question for list serve

 

I wholeheartedly agree with Dennis.  The extra few days we may have to wait for the BCI/FBI to come back more than make up for the issues and cost involved in hiring and beginning the training for an individual only to have to terminate them due to problems uncovered on the criminal background check.

 

Jerri

Jerri L. Elson, LSW/QIDP

Executive Director

Muskingum Residentials, Inc.
office:  740-453-5350
cell:  740-221-1646

 

 

On Tuesday, December 11, 2018, 8:15:43 AM EST, Dennis Grant <dgrant@ursdayton.org> wrote:

 

 

By rule you can allow them to work while waiting but I consider this a bad practice and somewhat risky.  

 

On Tue, Dec 11, 2018 at 7:53 AM Tami Bay (via opra_members list) <opra_members@opra.simplelists.com> wrote:

I didnt realize we could employ someone without the BCI in hand? So according to 

5123-2-2-02 we can have employees work while waiting on the BCI?

 

 We always wait on the BCI before having them take the med admin.





 

 

On Mon, Dec 10, 2018 at 3:41 PM, Anita Allen

Please see question below from one of our members.

 

 

Our program is looking at the delegated nursing training requirements and wondering how others are addressing it. 

 

Specifically, 5123-2-2-02, of course, indicates we may conditionally employ while waiting on the BCI:

 

 (7) A responsible entity may conditionally employ an applicant, for a period not to exceed sixty days, pending receipt of information concerning the applicant's criminal records check once the applicant submits to the responsible entity the statement required by paragraph (C)(5)(a) of this rule. The responsible entity shall terminate the applicant's employment if it is informed that the applicant has been convicted of or pleaded guilty to a disqualifying offense.

 

This is done with an affidavit.

 

The delegated nursing application indicates background check results must be obtained within the given time frame. We are wondering if the "specified time frame" means that it is acceptable to have the affidavit in hand and go forward with med admin training. Or must we wait for the actual background check results to be obtained (which would push potential training times back further)?

 

Any feedback would be appreciated.

 

 

 

 

 

 

 

 

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Dennis G. Grant

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4710 Old Troy Pike

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