U.S. Department of Health and Human Services 
Office of Inspector General 
National Background Check 
Program for Long-Term-Care 
Providers: An Interim 
Assessment 
Suzanne Murrin 
Deputy Inspector General for Evaluation and Inspections 
May 2022, OEI-07-20-00181  U.S. Department of Health and Human Services 
Office of Inspector General 
Report in Brief 
May 2022, OEI-07-20-00181 
Why OIG Did This Review  National Background Check Program for 
Background checks for employees 
Long-Term-Care Providers: An Interim 
of long-term-care facilities are an  
important safety measure that can   Assessment 
help protect some of the facilities  
most vulnerable populations.   
The  National Background Check 
More than 13 million beneficiaries   Key Takeaway  Program (Program) provides grants 
are served by long-term-care  
During the first years of  to States to  develop programs for 
facilities each  year, including the 
Program participation, both  conducting background checks of 
elderly, individuals in hospice care, 
Idaho and Mississippi were   prospective long-term-care  
and individuals with intellectual 
unable to implement some   employees via State and Federal 
disabilities.   
requirements and did not  criminal history records.  
The National  Background Check  consistently report  Federal  Twenty-seven States have completed 
Program (Program), enacted by  and State funds.   their participation in  the Program.  
legislation in 2010, assists States  Additionally, one State did  Two States continue their 
and territories (States) in   not report data to accurately   participation in the Program: Idaho 
developing and improving systems  assess Program outcomes.  and Mississippi. 
to conduct Federal and State 
background checks.  Included in 
this legislation is a mandate that   What OIG Found 
the Office of Inspector General 
OIG found that Idaho and Mississippi lacked State legislative authority to 
(OIG) produce an evaluation  of the 
implement some Program requirements.  Further, both States 
Program within 180  days of  
encountered challenges with  coordination between State-level  
Program completion. This 
departments responsible for seeking legislative authority.  
reportthe fifth in a series to  
supplement the mandated  
OIG found additional concerns with Mississippi.  First, Mississippi was 
evaluationreviews the last two 
unable to submit required data to the Centers for Medicare & Medicaid 
States that  are participating in the 
Services (CMS) to calculate determinations of ineligibility.  This is despite 
Program.  The interim review 
the fact that Mississippi conducted background checks during the first 
allows CMS to assist the States in  
years of Program participation.  Additionally, Mississippi and Idaho did 
fully implementing Program  
not consistently report  Federal and State funds on required quarterly 
requirements during participation.  
financial reports; this made it difficult for CMS to determine the ongoing 
In future work, we will assess the 
cost of Program implementation. 
Program overall. 
What OIG Recommends and How the Agency Responded 
How OIG Did This Review 
We reviewed grant monitoring  These  report findings  are  consistent with  findings  in previous OIG reports 
documents and financial reports to  about challenges that States experienced during Program participation.   
determine the extent to which   Therefore, we recommend that CMS continue to implement OIGs prior 
Idaho and Mississippi are working  recommendations for it to take appropriate actions to (1) encourage  
towards meeting Program  States to obtain  the necessary legislative authority from the State to fully 
requirements.  Specifically, we   implement Program requirements; and (2) require participating States to  
evaluated the States ability to   consistently submit data that allow CMS and each  State to calculate 
obtain legislative authority and to   determinations  of ineligibility.  In  addition, with  this report, we further 
coordinate between State-level   recommend that CMS ensure that participating States submit  accurate  
agencies.  Additionally, we 
quarterly reports.  CMS concurred with  this recommendation. 
evaluated States monitoring 
documents.    
TABLE OF CONTENTS 
 
 
BACKGROUND................................................................................................................................................ 1  
FINDINGS......................................................................................................................................................... 7  
Three years into the Program, Idaho and Mississippi lack State legislative authority to implement 
some Program requirements ................................................................................................................................................ 7  
Mississippi has not reported data to  assess Program outcomes as required; Idaho reported sufficient 
data................................................................................................................................................................................................. 8  
Mississippis and Idahos inconsistent reporting of Federal and State funds on required quarterly 
financial reports makes it difficult for CMS to determine the ongoing cost of Program implementation
 ......................................................................................................................................................................................................... 9  
CONCLUSION AND RECOMMENDATION ..............................................................................................11  
Ensure that participating States submit accurate quarterly reports .................................................................... 12  
AGENCY COMMENTS AND OIG RESPONSE ......................................................................................... 13  
DETAILED METHODOLOGY ....................................................................................................................... 14  
APPENDICES.................................................................................................................................................. 15  
Appendix A: Mandate for National Background Check Program Evaluation and Reports .........................15  
Appendix B: Idaho and Mississippi Expenditures for the National Background Check Program as of 
September 2021  ...................................................................................................................................................................... 16  
Appendix C: Related OIG Reports..................................................................................................................................... 17  
Appendix D: Beginning and Ending Dates of States Respective Programs .....................................................20  
Appendix E: Agency Comments ........................................................................................................................................ 21  
ACKNOWLEDGMENTS AND CONTACT ................................................................................................ 24  
Acknowledgments ..................................................................................................................................................................24  
Contact........................................................................................................................................................................................ 24  
ABOUT THE OFFICE OF INSPECTOR GENERAL. ................................................................................... 25  
ENDNOTES ................................................................................................................................................... 26  
 
 
   
BACKGROUND  
OBJECTIVES 
To provide an interim assessment of implementation of the National Background 
Check Programs for Long-Term-Care Providers in Idaho and Mississippi.  
 
The beneficiaries served by long-term-care providers include some of the most 
vulnerable populations.1   Among these beneficiaries are the elderly, individuals in 
hospice care, and individuals with intellectual disabilities.2 Over 13 million of these 
beneficiaries are served through long-term-care services in nursing homes and by 
other providers such as home health, hospice, and personal care service agencies.3  
Patient abuse, patient neglect, and misappropriation of property (i.e., theft) have been 
identified as widespread problems that cause harm to vulnerable beneficiaries 
receiving long-term-care services.4, 5, 6  Studies have shown that some nurse aides 
who were convicted of abuse, neglect, or theft had previous criminal convictions that 
could have been detected through background checks.7, 8 The development of 
thorough background checks can provide protections for beneficiaries who rely on  
long-term-care services.  
National Background Check Program   
The National Background Check Program (Program) is a voluntary grant program that 
was enacted by legislation in 2010 to assist State agencies that receive the grant 
(referred to as State or by the name of the specific State) in developing and improving 
systems to conduct Federal and State background checks.9, 10, 11  This legislation 
included the mandate for OIG to produce an evaluation of the Program within 180 
days of Program completion.12 As groups of States concluded the Program, OIG has 
published reports assessing their implementation of it. These reportsfour in total 
serve as supplements to the mandated evaluation.13, 14, 15, 16 They are designed to 
provide recommendations and support to the Centers for Medicare & Medicaid 
Services (CMS) as it assists States that are continuing in the Program.  This report is 
the fifth in a series of six reports; the sixth report will be a comprehensive review of 
the program per the mandate. See Appendix A for the reporting mandate for OIG.  
The Program provides States with funding for 3 years to identify efficient, effective, 
and economical procedures for conducting background checks of prospective 
employees who will provide care to vulnerable beneficiaries in their State.17  States are 
eligible to receive up to $3 million in Federal funding.  States are required to match 
the Federal funding by spending $1 of their own funds for every $3 of Federal funds 
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spent and report these expenditures in Federal Financial Reports (FFRs) for CMS to 
review.18  States can request up to 3 1-year extensions for the Program if needed.  
These extensions do not come with Federal funding unless the State has not used the 
$3 million allotted during the initial grant period.  See Appendix B for information 
related to Federal grant awards and State matching funds for the States in this 
evaluation.  
In addition to providing funding, CMS provides technical assistance and an 
assessment of States progress.  CMS provides these services through its technical 
assistance contractor (Contractor).19  The CMS Contractor works directly with States to 
develop their respective programs by offering support in all aspects of Program 
implementation. Additionally, the CMS Contractor monitors States progress towards 
Program implementation by reviewing what are collectively known as monitoring 
documents (i.e., project narratives, FFRs, cost expenditures, and grantee data files) 
and related documentation during Program participation.  
Selected requirements for participating States   
States participating in the Program must meet a variety of broad statutory and 
Program requirements (collectively referred to as Program requirements) that guide 
them in developing systems for conducting background checks.  States have some 
flexibility in how they implement Program requirements.  For example, States must 
define direct patient access employees, but each State has flexibility in determining 
which types of prospective employees to include in its Program.  The requirements 
evaluated in this report identify the types of prospective employees who should 
receive background checks, the sources that are used for conducting background 
checks, and the continuous monitoring of employees criminal histories.  See below 
for the list of 13 selected Program requirements.20     
    Determine which individuals are direct patient access employees. 
    Require all prospective direct patient access employees to undergo background 
checks.  
    Include the nine facility and provider types defined by the Program. 
    Identify disqualifying offenses. 
    Establish a Statewide program. 
    Collect applicants fingerprints for Federal/State checks. 
    Conduct checks of Federal criminal history.  
    Conduct checks of State criminal history.  
    Conduct checks of State abuse/neglect registry for applicants current States of 
residence.  
    Conduct checks of State abuse/neglect registry for applicants prior States of 
residence.  
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    Conduct searches of records of any proceedings in the State that may contain 
disqualifying information. 
    Notify facilities and providers of convictions identified through continuous 
monitoring.21    
    Report convictions to required databases.22   
Required types of background checks    
To conduct thorough background checks, States must include several types of 
background checks in their Program implementation.23 The required checks include 
the following: (1) a search of any databases and abuse registries of all known States in 
which the prospective employee has lived;24 (2) a check of State criminal history 
records; (3) a fingerprint-based check of Federal Bureau of Investigation (FBI) criminal 
history records;25, 26 and (4) a search of the records of any proceedings in the State 
that may contain disqualifying information about the prospective employee.27, 28    
Another type of background check is continuous monitoring.  Continuous monitoring 
occurs after an employee has been hired.  If an employee receives a criminal 
conviction after being hired, the States law enforcement agency informs the State 
agency and the State agency informs the facilities or providers of the conviction.    
To conduct the required types of background checks and continuous monitoring, 
States may need to coordinate with the States law enforcement department. 
Care settings that require background checks    
Participating States must implement all required background checks for prospective 
employees among the following nine types of long-term-care facilities or providers:  
    skilled nursing facilities; 
    nursing facilities; 
    home health agencies; 
    providers of hospice care; 
    long-term-care hospitals; 
    providers of personal care services;  
    providers of adult day care;  
    residential care providers that arrange for long-term-care services or provide 
long-term-care services; and 
    intermediate-care facilities for individuals with intellectual disabilities.29  
State legislative authority 
States are required to take the necessary steps towards obtaining any needed State 
legislative authority to implement requirements of the Program.30  States may require 
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new or amended State legislation to implement Program requirements regardless of 
the level of pre-existing infrastructure that States have when they enter the 
Program.31  States in the developmental stage may need to obtain legislative 
authority to build Program infrastructure, while States in the operational stage may 
need to seek updated legislative authority to improve existing infrastructure.  To 
obtain full legislative authority to implement all Program requirements, States may 
need to coordinate efforts among departments within their State.  Some State 
criminal justice authorities have the responsibility to seek legislation for Program 
requirements, such as the collection of applicant fingerprints and continuous 
monitoring.  
A State has flexibility in determining the appropriate order of seeking legislation and 
developing its program. One State might begin building program infrastructure 
(e.g., information systems) while working with its legislature to obtain the authority to 
conduct background checks.  Another State might decide to obtain legislative 
authority before building any program infrastructure.   
Required quarterly reporting  
States are required to submit quarterly reports to CMSs Contractor that include data 
to track the types and outcomes of background checks that are conducted.32  The 
data file that each State submits to the CMS Contractor should contain cumulative 
data from registry checks, State criminal history records, and FBI criminal history 
records (e.g., provider type, fingerprint collection date, employment eligibility 
determination, and employment eligibility determination date).  The CMS Contractor 
provides States in the Program with guidance and technical assistance regarding the 
data elements that should be contained in the file and, as needed, technical assistance 
for submitting their data. Additionally, in collaboration with the Contractor, CMS fully 
developed a Background Check System (BCS) that States can use to collect and report 
data that meet reporting requirements.  Some States enter the Program with an 
existing system for collecting and reporting data, while other States enter the 
Program without an established system. States with existing systems may need to 
modify their system to meet Program reporting requirements or may choose to 
implement the BCS.  
In addition to the quarterly reporting of data, States are required to submit quarterly 
financial reports to CMS.  The quarterly financial reports include FFRs and quarterly 
cost summaries that detail State spending of Federal and State funds.33, 34   CMSs 
Office of Acquisition and Grants Management (OAGM) reviews and validates the FFRs.  
CMSs contractor, under the direction of OAGM, reviews and validates the quarterly 
cost expenditure reports.  Both the FFRs and the quarterly cost expenditure report 
forms include line items for documenting cumulative expenditures of the Program.  
The States report the cumulative amounts expended from Federal funding and State 
matching funds. 
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Related Reports  
OIG has published several evaluations and issued multiple recommendations to CMS 
regarding the importance of background checks.  OIG released its first report specific 
to the Program in 2016 with two recommendations for CMS to (1) continue to work 
with participating States to fully implement their background check programs, and 
(2) improve required reporting by States to ensure that CMS can conduct effective 
oversight.35  CMS implemented these recommendations by doing the following: 
(1) providing States with individual technical assistance, data review, and data 
validation, and developing the National Background Check Program Interim Progress 
Report; and (2) providing States with assigned project officers, a technical assistance 
contractor, teleconferences, and a website. In 2019, OIG released its second and third 
Program-specific reports with a recommendation that CMS take appropriate action to 
encourage participating States to obtain necessary authority to fully implement 
Program requirements.36, 37   CMS continues to work with States to implement this 
recommendation by encouraging States to take advantage of technical assistance 
available from the Contractor.  In 2020, OIG released its fourth Program-specific 
report with two recommendations that CMS should (1) assist participating States to  
address the challenge of coordinating  between State-level departments; and 
(2) require participating States to consistently submit data that allow for CMS and 
each State to calculate determinations of ineligibility.38  CMS concurred with both 
recommendations and has implemented the first recommendation.  See Appendix C 
for additional detail and descriptions of related work.  
Methodology 
For Idaho and Mississippi, we conducted an interim assessment.  Both States entered 
the Program in June 2018 and extended participation in the Program until May 2022.  
The interim review allows CMS to assist the States in fully implementing Program 
requirements during participation.  Both States have the option to extend  
participation in the Program until 2024.  We reviewed documentation from the start 
of the Program in June 2018 through September 30, 2021.   
For Idaho and Mississippi, we evaluated the States ability to  obtain legislative 
authority and coordinate between State-level departments.  Additionally, we 
evaluated State-submitted documents that CMS uses to monitor the Program.  
COVID-19 may have delayed each States ability to implement Program requirements. 
Data Collection.  We obtained data from CMS to conduct our analysis.  We 
collected monitoring documents (i.e., project narratives, FFRs, cost expenditures, 
quarterly reports, assessments, and grantee data files) submitted by States related to 
their implementation of Program requirements.  We verified with CMS Program 
officials that the data we obtained from these sources were consistent with CMS 
records. 
Data Analysis. We used CMSs monitoring documents to assess States progress in 
meeting the requirements.  We evaluated the number and rate of background checks  
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that resulted in determinations of ineligibility for employment during the States grant 
participation.  Additionally, we evaluated each States expenditures for the Program. 
Standards 
We conducted this study in accordance with the Quality Standards for Inspection and  
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency. 
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FINDINGS 
Three years into the Program, Idaho and Mississippi lack State 
legislative authority to implement some Program requirements  
Both Idaho and Mississippi encountered challenges with implementing all selected 
Program requirements.  Idaho encountered challenges with making changes to 
current legislation and with efforts between two State-level departments to obtain 
new legislative authority to implement specific requirements.  Mississippi encountered  
challenges with the coordination between two State-level departments in obtaining 
the legislative authority to implement one requirement.   
At the time of our review, Idaho has not yet amended legislation that would allow it 
to implement select Program requirements.  Specifically, Idaho reported that under 
current State law, long-term-care applicants are not required to disclose prior 
residencies.  This limits Idahos ability to implement the Program requirement to 
conduct checks of State abuse and neglect registries for applicants prior States of 
residence. During Program participation, Idaho reported to CMS that the State has 
been considering the addition of the needed amended legislation.   
Further, according to documents submitted by the State to CMS, Idaho does not yet 
have the legislative authority to conduct continuous monitoring despite efforts to 
coordinate between State-level departments.  The Idaho Department of Health and 
Welfare is the State agency that is participating in the Program, and it is unable to 
implement continuous monitoring without the needed legislation.  However, the 
Idaho State Police are responsible for seeking the appropriate legal authority needed 
for the State to conduct continuous monitoring.  At this time, the Idaho State Police 
have not secured the needed legislative authority.   
Like Idaho, according to documents submitted by the State to CMS, Mississippi 
attempted but does not yet have the legislative authority to conduct continuous 
monitoring.39  Specifically, the Mississippi State Department of Health is the State 
agency that is participating in the Program; however, the Mississippi Department of 
Public Safety lacks the legislative authority to retain fingerprints for all long-term-care 
applicants. Retaining fingerprints is a necessary step to enact continuous monitoring,  
a Program requirement. The State and the Mississippi Department of Public Safety 
have received technical assistance from the CMS Contractor and continue working 
towards obtaining the needed legislation.  
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Mississippi has not reported data to assess Program outcomes 
as required; Idaho reported sufficient data 
Although both States entered the Program with existing systems for conducting 
Federal, State, and registry background checks, only Idaho began reporting data on 
these checks as required. 
Mississippi has not yet provided CMS with any data to assess Program outcomes.  
Mississippi entered the Program with an existing system for conducting Federal, State, 
and registry background checks. Although the State was conducting background 
checks during Program participation, its existing system was not configured to report 
the data elements required by the Program.  Despite some delays due to the  
COVID-19 pandemic, the State is still working with the CMS Contractor to implement 
a new system that would allow the collection of data elements required by the 
Program. This system was scheduled to be active in 2022.  See Exhibit 1 for an 
analysis of data submitted by States to CMS.  
Idaho reported the required data elements after receiving technical assistance from 
the CMS Contractor. Although Idaho conducted Federal, State, and some registry 
background checks, the system Idaho was using was not configured to report the 
data elements required by the Program.  The CMS Contractor worked with Idaho to 
ensure that the State reported the required data elements.  These data elements 
include background checks and determinations of ineligibility for the entirety of 
Program participation. The State is replacing its existing system and will continue to 
report the required data elements in the future.  
Exhibit 1: Only Idaho provided the numbers of background checks 
conducted and determinations of ineligibility made during the first years of  
Program participation. 
State  Completed  Checks with   Percentage 
Checks   Determinations  Determined 
of Ineligibility   Ineligible  
Idaho  32,214   4,922   15.28  
Mississippi*  Unknown  Unknown  Unknown 
Source: OIG analysis  of State background-check data, 2022. 
*Mississippi did not have  a system  that  allowed  reporting of required  data elements.  
 
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Mississippis and Idahos inconsistent reporting of Federal and 
State funds on required quarterly financial reports makes it 
difficult for CMS to determine the ongoing cost of Program 
implementation 
Although both States submitted quarterly financial reports, the reports included 
inconsistent details related to Federal and State contributions.  States are required to 
submit quarterly the cumulative amounts contributed by Federal funding and State 
matching funds. When State reporting does not match, it can impact CMS's ability to 
determine the ongoing cost of Program implementation. 
The September 2021 FFR and quarterly cost expenditure report submitted by 
Mississippi reflected Federal expenditures that differed by more than $15,000.  The 
September 2021 FFR reported that Mississippi spent roughly $339,000 in Federal 
funds. The quarterly cost expenditure report for the same quarter reported that 
Mississippi spent roughly $354,000 in Federal funds.  
Additionally, Mississippi did not consistently report contributing required State 
matching funds for every $3 of Federal funds spent.  Mississippi reported spending 
$339,017 in Federal funds in its FFR and $354,399 in Federal funds in its quarterly cost 
expenditure report. On the basis of these amounts, Mississippi is required to match a  
minimum of $113,006 on the implementation of the Program.  Prior to June 2021, 
Mississippi had not reported contributing State matching funds on either of the 
required financial reports. The FFR that Mississippi submitted for September 2021 
reflected that Mississippi had contributed State funds of $135,000 towards 
implementation of the Program.  For that same quarter, Mississippi did not report 
contributing any State funds towards the implementation of the Program in its CMS 
quarterly cost expenditure report. 
Exhibit 2: Mississippis State expenditures as reported in the quarterly cost 
expenditure report and FFR did not match for September 2021. 
Quarterly Report  Federal Funds  State Matching Funds  
FFR  $339,017   $135,000  
Quarterly Cost Expenditures  $354,399   $0 
Difference in Reporting  $15,382   $135,000  
Source: OIG analysis  of September 2021 FFRs and quarterly cost expenditure reports, 2022. 
Idahos September 2021 quarterly cost expenditure report and FFR also did not 
match. The CMS quarterly cost expenditure report that Idaho submitted for 
September 2021 reported spending $497,219 in Federal funds and $165,740 in State 
matching funds. The FFR that Idaho submitted for the same quarter reflected that 
Idaho spent $472,282 in Federal funds and $126,110 in State matching funds; this 
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State match differed by more than $39,000 between the two reports.  Further, the FFR 
State match figure did not meet the State matching funds requirement for every $3 of 
Federal funds spent. See Appendix B for States Program expenditures.  
Exhibit 3: Idahos State expenditures as reported in the quarterly cost 
expenditure report and FFR did not match for September 2021.  
Quarterly Report  Federal Funds  State Matching Funds  
FFR  $472,282   $126,110  
Quarterly Cost Expenditures  $497,219   $165,740  
Difference in Reporting  $24,937   $39,630  
Source: OIG analysis  of September 2021 FFRs and quarterly cost expenditure reports, 2022.   
 
 
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CONCLUSION AND RECOMMENDATION 
By preventing prospective employees with disqualifying offenses from being 
employed by long-term-care facilities and providers, State background check 
programs can help protect beneficiaries who rely on long-term-care services from 
abuse, neglect, and theft.  By implementing the Program requirements, States are 
better able to ensure that the prospective employees who need background checks 
are being screened, that multiple sources are used to conduct checks, and that 
criminal records are being continuously monitored.   
The findings of this report are consistent with our previous assessments of the 
Program. Like other States that have participated in the Program, Mississippi and 
Idaho encountered challenges in the implementation of some Program requirements 
because they lacked the State legislative authority required for implementation.  For  
Mississippi, these challenges included coordination between State-level departments 
to seek the necessary changes.  In addition, Mississippi and Idaho failed to report data 
required to assess Program outcomes.  A States failure to report could impact CMS's 
ability to determine the number of determinations of ineligibility made and the actual 
cost of Program implementation. 
CMS has made efforts to assist States with their unique needs in implementing 
Program requirements and reporting of required data based on past OIG findings and 
recommendations.  CMSs efforts included identifying potential barriers; providing 
States with targeted technical assistance; and sharing examples of lessons learned and 
best practices. CMS developed the National Background Check Program Interim 
Progress Report tool to evaluate States progress towards implementation of 
Program requirements and began reviewing and validating quarterly data submitted 
by States. Additionally, to address previous issues such as coordination between 
State-level departments, CMS developed a resource library and conducted yearly 
in-person training meetings. CMS continues to provide this assistance to States 
through its Contractor.  
Despite CMSs efforts in these areas, both Idaho and Mississippi lack needed 
legislative authority and Mississippi has not reported data required to assess Program 
outcomes. To address these issues, CMS should continue to work towards 
implementing the recommendations that OIG made in prior reports for CMS to (1) 
take appropriate actions to encourage States to obtain the necessary authority to fully 
implement Program requirements; and (2) require participating States to consistently 
submit data that allow CMS and each State to calculate determinations of 
ineligibility.40, 41  On the basis of this reports findings, we make a new 
recommendation.  
 
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We recommend that CMS: 
Ensure that participating States submit accurate quarterly 
reports 
CMS should ensure that the cost expenditure reports and FFRs submitted quarterly by 
States accurately reflect Federal and State funds spent.  CMS should do this by 
developing a practice for reviewing quarterly documents submitted by the States and 
by aiding Mississippi and Idaho, as needed, in ensuring compliance with the Federal 
and State matching funds requirement and expenditure reporting.  In the future, CMS 
should take immediate action to work with States when a States quarterly cost 
expenditure report and FFR do not match Federal and State expenditures for that 
quarter.  
 
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AGENCY COMMENTS AND OIG RESPONSE 
CMS concurred with OIGs recommendation to ensure that participating States submit 
accurate cost expenditure reports and FFRs.  CMS stated that it will continue to work 
closely with participating States to implement procedures for States to submit 
accurate quarterly reports.  CMS stated that it  will also continue to offer resources and 
a system for States to submit National Background Check Program compliant data.  
For the two States that continue participation,  CMS will establish an additional layer of 
validation review to support them in submitting quarterly reports that accurately 
reflect Federal and State funds spent.    
OIG appreciates CMSs continued efforts and the proposed additional review to 
address the submission of accurate quarterly reports. 
For the full text of CMSs comments, see Appendix E.  
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DETAILED METHODOLOGY 
Scope 
We evaluated two States that continue participation in the National Background 
Check Program (Program): Idaho and Mississippi.  Both States entered the Program in 
June 2018 and extended participation in the Program until May 2022.  The interim 
review allows CMS to assist the States  in fully implementing Program requirements 
during participation. Both States have the option to extend participation in the 
Program until 2024. We reviewed documentation from the start of the Program in 
June 2018 through March 31, 2021.  See Appendix D for a listing of all States that 
have participated in the Program. 
Congress directed OIG to analyze the most appropriate, efficient, and effective 
procedures for conducting background checks, as well as to assess the Program cost.  
We will reserve these analyses for the final rollup report once all States have 
completed the Program, which could occur as late as 2024.  See Appendix A for the 
reporting mandate. 
Data Collection  
CMS grant monitoring documents.  We obtained from CMS the reports and 
documents submitted by States related to their implementation of the Program.  We 
collected from CMS and the technical assistance contractor (Contractor) the 
monitoring documents that they received from each State.  We obtained the source  
amounts for Program funding from the Federal Financial Reports (FFRs), and we 
obtained Program costs from the quarterly cost expenditure reports.  We followed up 
with CMS, the Contractor, and Mississippi Program officials to verify our assessment 
of the documents received. 
Data Analysis  
We reviewed the documents that we obtained from CMS and the Contractor to 
evaluate States progress in the Program during the first 3 years of grant participation.   
We also reviewed the number of background checks that States conducted and 
analyzed the rates of determinations of ineligibility for prospective employees.  
Additionally, we reviewed the financial reports, including FFRs and quarterly cost 
expenditure reports, to identify the overall Program costs, including startup cost, 
administrative cost, and total costs. 
 
 
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APPENDICES 
Appendix A: Mandate for National Background Check Program 
Evaluation and Reports 
P.L. No. 111-148,  6201(a)(7) 
 6201(a)(7) EVALUATION AND REPORT. 
(A) EVALUATION. 
(i) IN GENERAL.The Inspector General of the Department of Health 
and Human Services shall conduct an evaluation of the nationwide 
program. 
(ii)INCLUSION OF SPECIFIC TOPICS.The evaluation conducted under 
clause (i) shall include the following: 
(I) A review of the various procedures implemented by participating 
States for long-term  care facilities or providers, including staffing 
agencies, to conduct background checks of direct patient access 
employees under the nationwide program and identification of the 
most appropriate, efficient, and effective procedures for conducting 
such background checks.  
(II)An assessment of the costs of conducting such background 
checks (including start up and administrative costs). 
(III) A determination of the extent to which conducting such 
background checks leads to any unintended consequences,  
including a reduction in the available workforce for long-term  care 
facilities or providers.  
(IV) An assessment of the impact of the nationwide program on 
reducing the number of incidents of neglect, abuse, and 
misappropriation of resident property to the extent practicable. 
(V) An evaluation of other aspects of the nationwide program, as 
determined appropriate by the Secretary. 
(B) REPORT.Not later than 180 days after the completion of the 
nationwide program, the Inspector General of the Department of Health 
and Human Services shall submit a report to Congress containing the 
results of the evaluation conducted under subparagraph (A). 
 
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OEI-07-20-00181   Appendix A | 15     
Appendix B: Idaho and Mississippi Expenditures for the National 
Background Check Program as of September 2021 
State Quarterly Cost Expenditure Reports 
State Quarterly   Federal  State  Total  
Cost Expenditure   Funds  Funds 
Reports 
Idaho  $497,219   $165,740   $662,959  
Mississippi  $354,399   $0  $354,399  
Source: CMS Quarterly Cost Expenditure ReportsSeptember 2021. 
Results are  rounded.  
State Federal Financial Reports 
State  Federal  State  Total  
Federal Financial   Funds  Funds 
Reports 
Idaho  $472,282   $126,110   $598,392  
Mississippi  $339,017   $135,000   $474,017  
Source: CMS Federal Financial ReportsSeptember 2021. 
Results are  rounded.  
 
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OEI-07-20-00181   Appendix B | 16     
Appendix C: Related OIG Reports  
NOTE: This current report and five of the nine reports listed belowi.e., our 
September 2020 report (OEI-07-20-00180), our August 2019 report (OEI-07-18-
00290), our April 2019 report  (OEI-07-16-00160), our 2016 report  (OEI-07-10-00420), 
and one of our 2012 reports (OEI-07-10-00421)all examine the same grant 
program. The 2016 and 2012 reports refer to it by slightly different names.  
National Background Check Program for Long-Term-Care Providers: Assessment 
of State Programs Concluded in 2019 (OEI-07-20-00180)    
In September 2020, OIG published an evaluation of the four States that concluded 
Program participation in 2019.  These four States varied as to the degree to which 
they were able to implement Program requirements.  One State had existing 
legislative authority and implemented all 13 selected Program requirements.  Three 
States did not fully implement Program requirements.  These States had varying 
degrees of State-level legal requirements and practical infrastructure for conducting 
background checks that affected their ability to implement select Program 
requirements.  Primarily, these States lacked legislative authority and encountered 
challenges in coordinating between State-level departments.   
In this evaluation, OIG recommended that CMS continue to implement OIGs prior 
recommendation that CMS take appropriate actions to encourage States to obtain 
the necessary legislative authority to fully implement Program requirements.  Given 
this reports findings, CMS should assist participating States to address the challenge 
of coordinating between State-level departments and require participating States to 
consistently submit data that allow for CMS and each State to calculate 
determinations of ineligibility.  CMS concurred with both recommendations and has 
implemented the first recommendation. 
National Background Check Program for Long-Term-Care Providers: Assessment 
of State Programs Concluded in 2017 and 2018 (OEI-07-18-00290)  
In August 2019, OIG published an evaluation  of the 11 States that concluded Program 
participation in 2017 and 2018.  These 11 States varied as to the degree to which they  
were able to implement Program requirements.  Two States implemented all selected 
Program requirements.  Nine States did not implement all the selected Program 
requirements, primarily because of a lack of legislative authority for certain Program 
requirements.  We encouraged CMS to implement an open recommendation from the 
April 2019 reportnamely, to take appropriate actions to encourage States to obtain 
the necessary legislative authority to fully implement Program requirements.  We did 
not offer any new recommendations.   
National Background Check Program for Long-Term-Care Providers: Assessment 
of State Programs Concluded Between 2013 and 2016 (OEI-07-16-00160)   
In April 2019, OIG published an evaluation of the National Background Check 
Program for Long-Term-Care Providers for the 10 States that concluded their 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Appendix C | 17     
participation by 2016.  These 10 States varied as to the degree to which they 
implemented Program requirements.  Seven of the States implemented all or most of 
the selected requirements.  Three States did not have the necessary authority through 
State legislation and could not fully implement background check programs. 
In this evaluation, OIG recommended that CMS take appropriate action to encourage 
participating States to obtain necessary authorities to fully implement Program 
requirements.  CMS concurred with this recommendation and continues working to 
implement this recommendation by providing supporting pre-legislative research and 
assisting States in developing revised legislative language, and has provided technical 
assistance to develop and promote effective legislation. 
National Background Check Program for Long-Term-Care Employees: Interim 
Report (OEI-07-10-00420)    
In 2016, OIG published an evaluation of the National Background Check Program for 
Long-Term-Care Employees that described the overall State implementation status 
during the first 4 years of the Program.  The 25 States participating in the grant 
Program reported hadving achieved varying levels of implementation.  Fifteen States 
did not conduct continuous monitoring of criminal convictions.  Thirteen States did 
not obtain legislation that would enable them to conduct background checks.  Ten 
States had not implemented processes to collect fingerprints.  The study provided 
CMS with information to assist in its ongoing administration of the Program. 
In this evaluation, OIG recommended that CMS continue working with States to fully 
implement their background check programs.  Additionally, OIG recommended that 
CMS continue working with participating States to improve the quality of their 
required data reporting to ensure that CMS can conduct effective oversight of the 
program. CMS concurred with both recommendations and implemented the first 
recommendation by providing States with individual technical assistance, data review, 
and data validation. CMS implemented the second recommendation by providing 
States with assigned project officers, a technical assistance contractor, 
teleconferences, and a website. 
Home Health Agencies Conducted Background Checks of Varying Types 
(OEI-07-14-00130)   
In 2015, OIG published an evaluation of the varying types of background checks 
conducted by home health agencies (HHAs); we reviewed selected employees whose 
convictions were likely to disqualify them from HHA employment.  We found that 
4 percent of HHA employees had at least one criminal conviction.  FBI criminal history 
records were not detailed enough to enable us to definitively determine whether 
employees with criminal convictions should have been disqualified from HHA 
employment. 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Appendix C | 18     
State Requirements for Conducting Background Checks on Home Health Agency  
Employees (OEI-07-14-00131)   
In 2014, OIG published an evaluation of State requirements for conducting 
background checks on HHA employees and surveyed State officials about their 
respective background check programs.  The evaluation found that 41 States required 
HHAs to conduct background checks on prospective employees.  Of the 10 States 
that had no requirements for background checks, 4 States reported that they planned 
to implement such requirements in the future.  Thirty-five States specified convictions 
that disqualified individuals from employment, and 16 States allowed an individual 
who had been disqualified from employment to apply to have his/her conviction(s) 
waived.  
Criminal Convictions for Nurse Aides with Substantiated Findings of Abuse, 
Neglect, and Misappropriation (OEI-07-10-00422)   
In 2012, OIG published an evaluation that found that nurse aides with substantiated 
findings of abuse, neglect, and/or misappropriation of property also had previous 
criminal convictions that could have been detected through background checks.  
Nineteen percent of nurse aides with substantiated findings had at least one 
conviction in their criminal history records prior to their substantiated finding.  
Among these nurse aides, the most common conviction (53 percent) was for crimes 
against property (e.g., burglary, shoplifting, and writing bad checks).  
Nationwide Program for National and State Background Checks for Long-Term-
Care EmployeesResults of Long-Term-Care Provider Administrator Survey 
(OEI-07-10-00421)  
In 2012, OIG conducted an evaluation of the nationwide Program for national and 
State background checks that surveyed long-term-care provider administrators.  We 
found that 94 percent of administrators conducted background checks on prospective 
employees. Twenty-three percent of surveyed administrators believed that their 
organizations background check procedures reduced the pool of prospective 
employees.  
Nursing Facilities Employment of Individuals with Criminal Convictions 
(OEI-07-09-00110)   
In 2011, OIG published an evaluation of individuals with criminal convictions 
employed in nursing home facilities that found that 92 percent of nursing facilities 
employed at least one individual with at least one criminal conviction.  Overall, 
5 percent of nursing facility employees had at least one criminal conviction.  In this 
evaluation, a national survey of nursing home facility administrators found that almost 
all facilities conducted some form of background check.  
OIG full reports can be found at www.oig.hhs.gov. 
 
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OEI-07-20-00181   Appendix C | 19     
Appendix D: Beginning and Ending Dates of States Respective 
Programs 
State  Grant Award Date  Scheduled Grant  Actual Grant End 
End Date*   Date 
Delaware   9/30/2010      9/29/2013  
Illinois   12/31/2010      12/30/2014  
Maryland   1/31/2013      1/30/2016  
Alaska   9/30/2010      9/29/2016  
Connecticut  9/30/2010      9/29/2016  
Florida  9/30/2010      9/29/2016  
Missouri  9/30/2010      9/29/2016  
Rhode Island   9/30/2010      9/29/2016  
District of Columbia   12/31/2010      12/30/2016  
New Mexico   12/31/2010      12/30/2016  
California  2/1/2011      1/31/2017  
Oklahoma   4/5/2011      4/4/2017  
Kentucky   5/20/2011      5/19/2017  
Michigan  5/20/2013      5/19/2017  
Utah   7/11/2011      7/10/2017  
North Carolina  7/13/2011      7/12/2017  
Maine   10/1/2011      9/30/2017  
Nevada   10/1/2011      9/30/2017  
West Virginia  10/1/2011      9/30/2017  
Georgia   7/25/2012     7/24/2018  
Minnesota   8/30/2012     7/31/2018  
Hawaii  12/17/2012     12/16/2018  
Ohio   4/22/2013     4/21/2019  
Oregon  7/29/2013     7/28/2019  
Puerto Rico*  12/17/2012     12/16/2019  
Wisconsin**  6/1/2018     6/26/2020  
Kansas   7/1/2015     6/30/2021  
Idaho***  6/1/2018   5/31/2022    
Mississippi***  6/1/2018   5/31/2022    
Source: CMS Notice of Award and the  CMS technical assistance contractor (Contractor) website.   Dates reflect the schedule as of  
March 2022.  
*Puerto Rico was awarded a 1-year extension in 2018 because of natural disasters experienced  by the State. 
**Wisconsin withdrew from the Program early.   
***Idaho and Mississippi have the  option of extending their  grant  periods to 2024.  Extensions may be  granted closer to States  
respective grant end dates.  
 
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OEI-07-20-00181   Appendix D | 20     
Appendix E: Agency Comments 
Following this page are the official comments from CMS.  
   
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Appendix E | 21     
 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Appendix E | 22     
 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Appendix E | 23     
ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Andrea Staples served as the team leader for this study, and Haley Lubeck and Jordan 
Swoyer served as analysts.  Office of Evaluation and Inspections staff who provided 
support include Christine Moritz and Michael Novello.  
This report was prepared under the direction of  Brian Whitley, Regional Inspector 
General for Evaluation and Inspections in the Kansas City regional office, and Dana 
Squires and Abbi Warmker, Deputy Regional Inspectors General. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov. OIG reports and other information can be found 
on the OIG website at oig.hhs.gov.  
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201  
 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   Acknowledgments and Contact | 24    
ABOUT THE OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 
95-452, as amended, is to protect the integrity of the Department of Health and 
Human Services (HHS) programs, as well as the health and welfare of beneficiaries 
served by those programs.  This statutory mission is carried out through a nationwide 
network of audits, investigations, and  inspections conducted by the following 
operating components: 
The Office of Audit Services (OAS)  provides auditing services for HHS, 
either by conducting audits with its own audit resources or by overseeing audit work 
done by others. Audits examine the performance of HHS programs and/or its 
grantees and contractors in carrying out their respective responsibilities and are 
intended to provide independent assessments of HHS programs and operations.  
These audits help reduce waste, abuse, and mismanagement and promote economy 
and efficiency throughout HHS.  
The Office of Evaluation and Inspections (OEI)  conducts national 
evaluations to provide HHS, Congress, and the public with timely, useful, and reliable 
information on significant issues.  These evaluations focus on preventing fraud, waste, 
or abuse and promoting economy, efficiency, and effectiveness of departmental 
programs. To promote impact, OEI reports also present practical recommendations 
for improving program operations. 
The Office of Investigations (OI)  conducts criminal, civil, and administrative 
investigations of fraud and misconduct related to HHS programs, operations, and 
beneficiaries. With investigators working in all 50 States and the District of Columbia, 
OI utilizes its resources by actively coordinating with the Department of Justice and 
other Federal, State, and local law enforcement authorities.  The investigative efforts 
of OI often lead to criminal convictions, administrative sanctions, and/or civil 
monetary penalties. 
The Office of Counsel to the Inspector General (OCIG) provides 
general legal services to OIG, rendering advice and opinions on HHS programs and 
operations and providing all legal support for OIGs internal operations.  OCIG 
represents OIG in all civil and administrative fraud and abuse cases involving HHS 
programs, including False Claims Act, program exclusion, and civil monetary penalty 
cases. In connection with these cases, OCIG also negotiates and monitors corporate 
integrity agreements. OCIG renders advisory opinions, issues compliance program 
guidance, publishes fraud alerts, and provides other guidance to the health care 
industry concerning the anti-kickback statute and other OIG enforcement authorities. 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181   About the Office of Inspector General | 25    
ENDNOTES 
 
1 CMS, Nationwide Program for National and State Background Checks for Direct Patient Access Employees of Long Term Care 
Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 5.   
2 Ibid. 
3 Summation by OIGs Division of Data Analytics regarding unique beneficiaries receiving services in 2019 from each of the 
care settings covered by the Program.   
4 CMS, Nationwide Program for National and State Background Checks for Direct Patient Access Employees of Long Term Care 
Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 5.   
5 OIG, Criminal Convictions for Nurse Aides with Substantiated Findings of Abuse, Neglect, and Misappropriation, 
OEI-07-10-00422, October 2012.   
6 OIG, Vulnerabilities in Medicare Hospice Program Affect Quality Care and Program Integrity: An OIG Portfolio, 
OEI-02-16-00570, July 2018. 
7 Ibid. 
8 Office of Disability, Aging and Long-Term Care Policy,  Ensuring a Qualified Long-Term Care Workforce: From Pre-
Employment Screens to On-the-Job Monitoring, May 2006. Accessed at 
https://aspe.hhs.gov/system/files/pdf/74676/LTCWqual.pdf on September 14, 2006. 
9 The National Background Check Program was named in legislation as the Nationwide Program for National and State 
Background Checks on Direct Patient Access Employees of Long-Term Care Facilities and Providers.  In this report, we refer to 
it as the National Background Check Program or Program.  
10 P.L. No. 111-148,  6201. 
11 For the purpose of this report, State refers to the State department that is participating in the Program.  
12 P.L. No. 111-148,  6201(a)(7). 
13 OIG, National Background Check Program for Long-Term-Care Employees: Interim Report, OEI-07-10-00420, January 2016. 
14 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded Between 
2013 and 2016, OEI-07-16-00160, April 2019.   
15 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded in 2017 
and 2018, OEI-07-18-00290, August 2019.   
16 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded in 2019, 
OEI-07-20-00180, September 2020. 
17 CMS, Nationwide Program for National and State Background Checks for Direct Patient Access Employees of Long Term Care  
Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 6.   
18 P.L. No. 111-148,  6201(a)(5). CMS,  Nationwide Program for National and State Background Checks for Direct Patient Access 
Employees of Long Term Care Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 
19. 
19 CMS, Nationwide Program for National and State Background Checks for Direct Patient Access Employees of Long Term Care 
Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 5. 
20 P.L. No. 111-148,  6201(a). 
 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181  Endnotes | 26   
 
21 P.L. No. 111-148,  6201(a)(4)(B)(viii).  Continuous monitoring, or rap back capability, means that if an employee receives a 
criminal conviction subsequent to the pre-employment background check, the States law enforcement informs the State 
agency. In turn, the State agency informs the facility or provider that has hired the employee with the conviction.  Once a 
State has implemented continuous monitoring of criminal convictions, there is no further need for employers to conduct 
future periodic criminal background checks on employees.  
22 P.L. No. 111-148,  6201(a)(4)(B)(v)(IV).  A prospective employee who is determined ineligible shall be reported to the 
appropriate State or local agency.   
23 P.L. No. 111-148,  6201(a)(3)(A).  
24 The grant solicitation document that CMS published defines registries as any State-based databases and nurse aide  
registries that identify those who have been  approved under State requirements to provide care to residents or patients in 
long-term-care facilities or by providers of long-term-care services.  These registries may includebut are not limited to 
registries that list physicians, nurses, psychologists, and other professionals who are considered direct patient access 
employees. In addition, other registries or databases may include the Medicare Exclusion Database, the Fraud Investigation 
Database, the Healthcare Integrity and Protection Data Bank, or the National Practitioner Data Bank.  CMS, Ninth 
Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 50.   
25 CMS established regulations that prohibit long-term-care facilities and providers from employing individuals found guilty 
of abuse, neglect, or misappropriation of patient funds.  In 1998, Congress enacted [P.L.] 105-277, which allows long term 
care facilities to request the [FBI] search its fingerprint database for criminal history matches.  CMS, Ninth Announcement 
CFDA #93.506 (CMS-1A1-13-002), May 2013, p. 5.   
26 42 U.S.C.,  1320a-7.  Under this statute, individuals may be excluded from participation in Federal health care programs on 
the basis of convictions of program-related crimes; patient abuse; and felony convictions related to health care fraud and 
controlled substances.  Other convictions may lead to permissive exclusionallowing the Secretary discretion as to whether 
to exclude the person even if he or she has a conviction.  These apply to both Federal and State convictions.  Under 42 U.S.C.,  
 1320a-7a, civil monetary penalties may be imposed on facilities that receive Federal health care dollars and that employ or 
contract with individuals whom the facilities know or should have known are excluded by the Secretary.   
27 P.L. No. 111-148,  6201(a)(3)(A).  Participating States must ensure that background checks include checks of (1) State 
criminal history records for relevant States; and (2) the records of any proceedings that may contain disqualifying information, 
such as the proceedings of licensing and disciplinary boards and State Medicaid Fraud Control Units.    
28 Criteria for disqualification are based on Federal and State laws.  Federal regulation prohibits Medicare and Medicaid 
nursing facilities from employing individuals who have been found guilty by a court of law of abusing, neglecting, exploiting, 
or mistreating residents or misappropriating residents property; who have had a finding entered into the State nurse aide 
registry concerning abuse, neglect, exploitation, or mistreatment of residents or misappropriation of residents property; or 
who have had a disciplinary action in effect against their professional license as a result of a finding of abuse, neglect, 
exploitation, or mistreatment of residents or misappropriation of residents property (42 CFR,  483.12(a)(3)).  State laws vary 
with regard to the types of convictions that disqualify prospective employees from employment in long-term care.  
29 P.L. No. 111-148,  6201(a)(6)(E). 
30 P.L. No. 111-148  6201(a)(4).  CMS, Notice of Award Patient Protection and Affordable Care Act Sec. 6201  Idaho, May 
2018, p. 41.  CMS, Notice of Award Patient Protection and Affordable Care Act Sec. 6201  Mississippi, May 2018, p. 41. 
31 CMS, Availability of Technical Assistance for Grantee States.  Accessed at https://www.bgcheckinfo.org/about-
nbcp/technical-assistance-overview on April 6, 2020. 
32 CMS, Nationwide Program for National and State Background Checks for Direct Patient Access Employees of Long Term Care 
Facilities and Providers, Ninth Announcement CFDA #93.506 (CMS-1A1-13-002), May 2013, pp. 19-20.  National Background 
Check Technical Assistance,  Quarterly Report Forms. Accessed on October 26, 2021.  CMS,  Notice of Award Patient Protection 
and Affordable Care Act Sec. 6201  Idaho, May 2018, p. 42. CMS, Notice of Award Patient Protection and Affordable Care Act  
Sec. 6201  Mississippi, May 2018, p. 42. 
33 Per the Terms and Conditions of the grant, CMS will specify the format and content of the quarterly reports (including the 
SF-425 and Federal Financial Report (FFR) forms). On the technical assistance website for the Program, CMS has indicated 
 
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181  Endnotes | 27   
 
that the four sections of the quarterly reports include the FFR, cost expenditure report, grantee data file, and project narrative 
(new as of October 5, 2021). The quarterly reports, FFRs, and grantee data files were accessed at 
https://www.bgcheckinfo.org/resources/useful-references-and-templates/quarterly-reports-forms on February 20, 2022. 
34 CMS, Notice of Award Patient Protection and Affordable Care Act Sec. 6201  Idaho, May 2018, p. 46.  CMS,  Notice of Award 
Patient Protection and Affordable Care Act Sec. 6201  Mississippi, May 2018, p. 46. 
35 OIG, National Background Check Program for Long-Term-Care Employees: Interim Report, OEI-07-10-00420, January 2016. 
36 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded Between 
2013 and 2016, OEI-07-16-00160, April 2019.   
37 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded in 2017 
and 2018, OEI-07-18-00290, August 2019.   
38 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded in 2019, 
OEI-07-20-00180, September 2020.  
39 Mississippi drafted legislation in 2018 that was sent to the FBI for review and approval.  The Federal government shutdown 
between December 22, 2018, and January 25, 2019, halted the process.  The COVID-19 pandemic beginning in March 2020 
may have further contributed to delays. 
40 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded between 
2013 and 2016, OEI-07-16-00160, April 2019.   
41 OIG, National Background Check Program for Long-Term-Care Providers: Assessment of State Programs Concluded in 2019, 
OEI-07-20-00180, September 2020.   
National Background Check Program for Long-Term-Care Providers: An Interim Assessment   
OEI-07-20-00181  Endnotes | 28