Background Checks and TB Testing for Home Health

For Medicare-certified home health agencies (HHAs), compliance with background check and tuberculosis (TB) testing requirements is essential — not only for patient safety but also for passing state and federal surveys. Surveyors closely examine these areas because they directly relate to the safety and quality of patient care.

Failure to maintain proper documentation can result in survey deficiencies, condition-level citations, and in severe cases, jeopardize your Medicare certification.

Background Checks in Home Health

Why They Matter

Background checks help protect vulnerable patients by ensuring that all employees — clinical and non-clinical — have no history of crimes that could compromise safety.

Survey Requirements

Surveyors expect to see:

1. Criminal Background Check Results for every employee, volunteer, and contracted worker providing direct patient care.

2. Documentation Date showing the check was completed before the individual had any patient contact.

3. Ongoing Monitoring procedures, if required by state law, for periodic re-checks.
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Surveyor Review Process

During an HHA survey, surveyors will:

• Randomly select employee files from various disciplines (RN, LVN, therapists, aides, office staff).

• Verify that the background check date precedes the employee’s hire date or start of patient care.

• Ensure the results meet state-specific criminal background standards.

• Confirm there is a policy in place for addressing findings of concern.
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Common Deficiencies Found:

• Missing background check results in personnel files.

• Checks conducted after an employee started patient care.

• No policy for handling adverse findings.

TB Testing in Home Health

Why It Matters

TB testing protects both patients and staff by identifying active or latent TB infections before employees enter the home setting.

Survey Requirements

Surveyors will look for:

1. Baseline TB Testing (skin test or blood assay) before the start of patient care.

2. Annual TB Screening for ongoing staff, per CDC and state guidelines.

3. Clear Documentation in the employee’s health record, signed and dated by a qualified healthcare provider.

4. Follow-Up Procedures for positive results, including medical clearance before patient contact.
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Surveyor Review Process

Surveyors will:

• Select a sample of employee health records.

• Confirm TB testing was completed before the employee had patient contact.

• Check for documentation of annual re-testing or screening questionnaires.

• Ensure that follow-up actions for positive results are documented and completed.
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Common Deficiencies Found:

• Missing TB test results in personnel files. Learn More

• Delays between hire date and TB testing completion.

• No evidence of annual screening for ongoing employees.

Best Practices for Passing Surveys

1. Maintain Organized Personnel Files

   • Keep background check reports and TB test results in a clearly labeled section of each employee’s file.

   • Include all dates, signatures, and supporting documentation.

2. Conduct Pre-Employment Checks

   • Complete background checks and TB testing before any patient contact.

   • Make this a mandatory hiring requirement in your HR policy.

3. Implement a Compliance Tracking System

   • Use digital HR software or compliance logs to track due dates for annual TB testing and re-checks.

4. Prepare for Surveyor Questions

   • Train HR and administrative staff to quickly retrieve background check and TB documentation.

   • Ensure all policies match actual practices.
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How HealthBridge Consulting Can Help

At HealthBridge Consulting, we work with home health agencies to ensure full compliance with background check and TB testing requirements, so you can pass surveys without deficiencies.

Our services include:

• Pre-Survey Compliance Audits of personnel files

• Policy & Procedure Development for background checks and TB screening

• Survey Readiness Training for HR and administrative teams

• Mock Surveys to identify and fix deficiencies before the real inspection

With our expertise, you can be confident that your agency is ready for any surveyor review — protecting both your patients and your Medicare certification.

Takeaway:
Background checks and TB testing are non-negotiable compliance areas in home health. The key to passing surveys is completing them before patient contact, documenting them clearly, and maintaining ongoing monitoring.

Contact HealthBridge Consulting today to prepare your agency for a flawless survey outcome.

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