Ohio Nursing Home Background Check Requirements: 2025 Compliance Guide

Written by   Published on 19 Nov 2025

Ohio nursing homes operate under a distinctive conditional employment framework that permits facilities to hire qualified candidates before completing comprehensive background checks, provided they meet specific Ohio Department of Health (ODH) database screening requirements within 48 hours. This dual-track screening process combines state-level Bureau of Criminal Investigation and Identification (BCI&I) checks with FBI federal screening, supplemented by ongoing RAPBACK monitoring obligations to ensure continuous compliance with ORC 3721.121 disqualifying offense categories throughout employment tenure. Facilities should consult employment counsel to develop compliant screening policies, as background check requirements involve complex legal standards that general guidance cannot fully address for facility-specific circumstances.

Key Takeaways

  • Ohio nursing homes can conditionally employ candidates immediately after conducting ODH database checks within 48 hours, allowing faster hiring while awaiting complete BCI&I and FBI background check results that typically take 1-4 weeks, though processing may extend to 6 weeks during high-volume periods or for complex cases.
  • The dual-track Ohio nursing home employee screening process requires both state criminal history checks through BCI&I and federal screening via FBI, with facilities maintaining ongoing RAPBACK enrollment for real-time criminal activity notifications, though all regulatory requirements should be verified with legal counsel as interpretations evolve.
  • ORC 3721.121 identifies over 40 disqualifying offense categories including violent crimes, theft-related convictions, drug trafficking, patient abuse, and healthcare fraud, with specific lookback periods requiring legal analysis—facilities must consult employment counsel for criminal record evaluations rather than relying on general guidance for specific hiring decisions.
  • Conditional employment provisions allow nursing homes to address urgent staffing needs while meeting regulatory obligations, though supervision requirements vary by employee role and facilities must immediately terminate employees if disqualifying offenses appear during screening.
  • Ohio healthcare worker screening process costs range from $70-105 per candidate as of 2025, covering fingerprinting services, BCI&I processing fees, FBI checks, and annual RAPBACK monitoring charges, though facilities should verify current pricing with approved vendors as fees may change.
  • Long-term care facilities must re-screen employees every five years and maintain comprehensive documentation of all background checks, database queries, and supervisory oversight during conditional employment periods, with legal counsel guidance recommended for RAPBACK-related re-screening questions.
  • Nursing home employment requirements extend beyond criminal background checks to include abuse registry searches across the ODH Nurse Aide Registry, Medicaid exclusion lists, and federal OIG sanctions databases, with FCRA adverse action procedures requiring strict compliance to avoid statutory penalties.
  • Employment offers must clearly state that hiring is conditional pending satisfactory background check completion, with explicit employer rights to terminate immediately if disqualifying information emerges, and facilities should have employment counsel review all conditional offer letter templates to ensure proper legal protections.

Understanding Ohio's Conditional Employment Framework

Ohio stands apart from most states by offering nursing homes a practical solution to urgent staffing challenges through its conditional employment provision. This framework, established under Ohio Administrative Code 3701-18-04, recognizes the critical need for qualified healthcare workers while maintaining rigorous safety standards for vulnerable residents. Facilities implementing conditional employment programs should consult healthcare compliance counsel to ensure their policies meet evolving regulatory interpretations and adequately protect both residents and the organization.

The conditional employment model allows facilities to bring new hires on board immediately after completing preliminary ODH database checks. This approach balances protecting nursing home residents from individuals with disqualifying criminal histories while enabling facilities to maintain adequate staffing levels. The framework addresses two competing priorities that previously created operational challenges for long-term care facilities across the state.

The 48-Hour Database Screening Window

Before any candidate begins work under conditional employment status, nursing homes must conduct thorough searches of specific ODH-maintained databases within 48 hours. The 48-hour timeframe begins when the employee first provides direct care or has unsupervised access to residents. Facilities must document the exact date and time of these searches.

Required database searches include the following critical resources:

  • Ohio Nurse Aide Registry: Identifies individuals with substantiated abuse, neglect, or misappropriation findings
  • State Abuse Registries: Reveals documented patterns of vulnerable adult mistreatment
  • Medicaid Exclusion Lists: Shows providers barred from federally funded healthcare programs
  • OIG LEIE Database: Federal exclusions for healthcare fraud and patient abuse
  • SAM Exclusion Lists: Government-wide debarment and suspension records

Many HR directors schedule these database checks on the candidate's first day to meet this critical deadline. Proper documentation creates essential evidence during state inspections and potential liability investigations.

Role-Specific Supervision Standards

During the conditional employment period, facilities must implement supervision protocols that vary based on employee roles and resident contact levels. OAC 3701-18-04(C) establishes different supervision standards depending on job classification. This creates complexity that requires careful policy development with legal counsel guidance.

Direct care positions including nursing assistants and medication aides require supervisors to maintain line-of-sight observation. Fully screened supervisors must maintain physical presence in the same immediate area where conditionally employed workers provide resident care. For dietary, housekeeping, or maintenance positions with resident access but not direct care responsibilities, facilities may implement same-unit supervision where fully screened supervisors remain available in the general work area.

Facilities should develop written supervision protocols for each job classification. Employment counsel should review these protocols to ensure compliance with Ohio regulatory standards. Documentation must include supervisor names, credentials, shift times, and attestations confirming continuous oversight according to role-appropriate standards.

Background Clearance Timelines

The complete Ohio nursing home background check requirements process typically spans 1-4 weeks from fingerprint submission to final clearance. However, timelines may extend to 6 weeks or longer based on several factors. FBI processing volumes, multi-jurisdiction inquiries, and the complexity of an applicant's criminal history across multiple states all affect processing speed.

Facilities should establish internal tracking systems that monitor each candidate's progress through the screening pipeline. These systems should flag cases approaching deadlines for follow-up. Processing delays create operational challenges when multiple conditional employees await clearance simultaneously, potentially straining supervisory resources and limiting facility flexibility in shift scheduling.

The Dual-Track Criminal Screening Process

Ohio nursing home employee screening operates through a comprehensive dual-track system that examines both state and federal criminal records. The Bureau of Criminal Investigation and Identification (BCI&I) conducts state-level screenings that reveal Ohio criminal convictions, arrests, and pending charges. Simultaneously, FBI screening searches the National Crime Information Center (NCIC) database and Interstate Identification Index, capturing criminal activity across all 50 states and U.S. territories.

This two-pronged approach ensures facilities identify disqualifying offenses regardless of where convictions occurred. Both screenings prove mandatory for nursing home positions involving resident care or access to personal property. The dual-track system provides thorough protection for vulnerable nursing home populations who depend on facilities for daily care and safety.

State-Level BCI&I Screening

BCI&I state background checks form the foundation of Ohio's nursing home screening requirements. Facilities submit applicant fingerprints electronically through approved channelers or via hardcopy fingerprint cards mailed directly to BCI&I headquarters in London, Ohio. Electronic fingerprint submission through approved vendors typically yields results within 3-7 business days, significantly faster than traditional ink-and-roll cards that may require 2-3 weeks for processing.

Screening ComponentProcessing TimeApproximate Cost
BCI&I State Check3-7 business days (electronic)$35-50 total
FBI Federal Check1-3 weeks (may extend to 6+ weeks)$35-55 total
RAPBACK EnrollmentAutomatic with fingerprints$2.50-3.00 annually

The BCI&I report details all Ohio criminal convictions, pending charges, arrest records, and dispositions available in state databases. Current BCI&I processing fees stand at approximately $22 per applicant as of 2025, though facilities should verify current pricing directly with BCI&I as fees may change. Total costs for the state screening component generally range from $35-50 per candidate when combining BCI&I fees with fingerprinting service charges.

Federal FBI Background Checks

FBI screening provides the federal component of Ohio's dual-track system, searching national databases that compile criminal records from state and federal law enforcement agencies nationwide. This screening proves essential for identifying candidates with disqualifying offenses committed outside Ohio's borders. The FBI processes fingerprints submitted through approved channelers, cross-referencing prints against millions of criminal records maintained in federal databases.

Processing times average 1-3 weeks for straightforward cases. Complex cases involving multiple jurisdiction inquiries may extend to 4-6 weeks or longer during high-volume periods. Results arrive through the same channeler that submitted fingerprints, who forwards reports to the nursing home facility.

RAPBACK Continuous Monitoring

Ohio nursing homes must enroll all employees in the Retention and Processing of Background Activity and Criminal Events (RAPBACK) program. This provides ongoing notification of new criminal activity throughout employment. RAPBACK enrollment occurs automatically when facilities submit fingerprints for initial BCI&I and FBI screening, provided they designate the submission as a "retention" rather than "single-use" fingerprint check.

Once enrolled, the system alerts facilities within 24-48 hours when enrolled employees face new arrests, charges, or convictions. Annual RAPBACK maintenance fees currently cost approximately $2.50-3.00 per enrolled employee, though facilities should verify current pricing with their fingerprinting vendors as fees may adjust. Compliance officers should establish procedures for responding to RAPBACK notifications.

Disqualifying Offenses Under ORC 3721.121

Ohio Revised Code Section 3721.121 establishes comprehensive categories of disqualifying offenses that permanently or temporarily bar individuals from nursing home employment. The statute contains over 40 specific offense categories with complex lookback periods requiring legal analysis for proper application. Facilities must never rely solely on general guidance articles for specific hiring decisions involving criminal records, as proper evaluation requires employment counsel review of complete statutory text, individual offense elements, and applicant-specific circumstances.

The statute distinguishes between permanently disqualifying offenses that create lifetime employment bars and temporarily disqualifying convictions with specific lookback periods. Understanding these distinctions proves essential for HR directors evaluating candidate backgrounds. However, the complexity of offense categorization and element-by-element legal analysis makes professional legal guidance necessary for any non-clear-cut criminal record evaluation.

Permanent Employment Bars

Certain offense categories create permanent employment bars regardless of how much time has elapsed since conviction. These permanently disqualifying offenses reflect the legislature's determination that certain crimes demonstrate such fundamental unfitness for nursing home work that no rehabilitation period can overcome the risk to vulnerable residents. Facilities have no discretion to waive these bars.

Permanently disqualifying offense categories include the following:

  • Murder and Manslaughter: Reflects extreme violence incompatible with patient care responsibilities
  • Sexual Offenses: Including rape, sexual battery, and gross sexual imposition involving minors
  • Kidnapping: Demonstrates propensity for controlling and harming vulnerable individuals
  • Patient Abuse with Serious Harm: Directly relates to nursing home resident safety concerns
  • Healthcare Fraud Causing Injury: Specific fraud statutes including Medicaid fraud and identity theft in healthcare contexts
  • Multiple Convictions: Patterns of certain lesser offenses within specified timeframes trigger permanent bars

Given the complexity of multiple-conviction analysis, facilities should consult employment counsel whenever candidate backgrounds involve more than one criminal conviction. Even if individual offenses appear non-disqualifying, the combination may create permanent bars under Ohio law.

Temporary Disqualifications

Temporarily disqualifying offenses create employment bars extending specific periods from conviction dates, after which candidates become eligible for nursing home positions. Common categories include single convictions for theft, drug possession (non-trafficking), assault, domestic violence, and certain financial crimes. However, ORC 3721.121 contains numerous additional categories requiring statutory review for complete understanding.

Lookback periods vary by offense severity, typically ranging from 3-10 years from conviction or release from incarceration, whichever comes later. Calculating lookback periods requires careful attention to conviction dates, sentencing terms, and release dates from incarceration or supervision. The clock starts when the individual completes all aspects of their sentence, including probation, parole, and post-release control.

Out-of-state convictions require particularly complex analysis to determine whether they constitute "substantially similar" offenses to Ohio disqualifying crimes. This determination demands element-by-element legal comparison of offense statutes that non-lawyers cannot reliably conduct. Facilities must obtain legal review for all out-of-state criminal records before making employment decisions.

Required Registry and Exclusion Searches

Ohio nursing home disqualifying offenses extend beyond criminal convictions to include listings on various abuse registries and healthcare exclusion databases. Facilities must search multiple databases to ensure comprehensive screening. The ODH Nurse Aide Registry maintains records of complaint investigations resulting in sustained findings against certified nurse aides.

DatabasePurposeDisqualification Effect
Nurse Aide RegistryTracks substantiated abuse findingsEmployment bar until successful appeal
OIG LEIEFederal healthcare exclusionsCannot work in Medicare/Medicaid facilities
SAM ExclusionsGovernment-wide debarmentsBars employment in federally funded programs

A notation on the Nurse Aide Registry creates an employment bar until the individual successfully challenges and removes the listing through ODH's appeal process. Federal exclusion databases present additional screening obligations. Individuals appearing on OIG LEIE or SAM databases cannot work in facilities receiving Medicare or Medicaid reimbursement, effectively barring them from virtually all Ohio nursing homes.

Implementing Compliant Screening Procedures

Implementing compliant Ohio nursing home background check requirements demands systematic processes that ensure consistency, maintain documentation, and meet all statutory deadlines. Successful facilities develop standardized protocols that guide every background check from candidate offer through final clearance and ongoing monitoring. Employment counsel should review all screening policies to ensure FCRA compliance and regulatory adequacy.

Pre-Employment Disclosures and Conditional Offers

The screening process begins with detailed application disclosures informing candidates about background check requirements and disqualifying offense categories. Ohio law requires written authorization from applicants before conducting criminal background checks. This satisfies both state requirements and federal Fair Credit Reporting Act (FCRA) mandates.

Employment offers for conditionally hired employees must include specific protective language:

  • Conditional Status: Clear statement that employment is conditional pending satisfactory background check completion
  • Termination Rights: Explicit right to terminate immediately if disqualifying information emerges
  • At-Will Employment: Disclaimers confirming either party may terminate at any time
  • No Guaranteed Duration: Confirmation that conditional employment creates no guarantee of permanent employment
  • Background Check Scope: Description of all screening components including criminal checks and database searches

Facilities should have employment counsel review all conditional offer letter templates. Proper language protects facilities from wrongful termination claims and promissory estoppel arguments when background checks reveal disqualifying information. Sample language might state: "This offer is conditional pending satisfactory completion of required background checks. Employment may be terminated immediately if background checks reveal disqualifying information."

Fingerprinting and Electronic Submission

Once candidates accept conditional employment offers, facilities must promptly arrange fingerprinting appointments. Ohio regulations require fingerprint-based background checks rather than name-based database searches. This ensures accurate identification and comprehensive criminal history retrieval.

Most facilities partner with approved electronic fingerprinting vendors who capture prints digitally and transmit them directly to BCI&I and FBI simultaneously. This electronic submission approach dramatically accelerates processing compared to traditional ink fingerprint cards. Candidates typically schedule fingerprinting appointments within 24-48 hours of accepting offers.

FCRA-Compliant Adverse Action Steps

When background checks reveal potentially disqualifying information, employers must follow strict FCRA adverse action procedures. These procedures protect candidates' rights while shielding facilities from federal statutory penalties of $100-$1,000 per violation plus actual damages and attorney fees. FCRA violations create significant liability exposure that facilities must avoid through meticulous compliance.

Pre-adverse action requirements include providing the candidate with a complete copy of the background check report and the FTC-mandated Summary of Consumer Rights Under FCRA. Facilities must allow reasonable time to dispute accuracy, typically 5 business days though no federal minimum exists. Employment counsel should help facilities establish appropriate timeframes for their specific circumstances.

During the dispute period, facilities should place conditionally employed workers on administrative leave without resident access. This protects residents while respecting candidates' dispute rights. Post-adverse action procedures after final termination decisions require providing written adverse action notice stating the background check was the termination reason, including Consumer Reporting Agency (CRA) contact information, and clarifying that the CRA did not make the employment decision.

Managing Ongoing Compliance Obligations

Successful conditional employment programs require robust administrative systems tracking multiple concurrent screening processes. Facilities must balance operational needs against regulatory obligations, ensuring conditionally employed workers contribute productively while remaining under appropriate oversight. Given the heightened liability standards nursing homes face due to resident vulnerability, facilities should implement supervision protocols exceeding minimum regulatory requirements.

Tracking Systems and Documentation

Facilities managing multiple conditional employees simultaneously need systematic tracking mechanisms monitoring each candidate's screening progress. Spreadsheet-based systems should capture fingerprint submission dates, database search completion, BCI&I result receipt, FBI clearance status, and RAPBACK enrollment confirmation. These systems should include milestone-based alerts for cases approaching critical deadlines.

When background checks reveal disqualifying offenses, facilities must act swiftly while completing required FCRA procedures. Meticulous documentation of the entire adverse action process protects facilities during employment litigation. Given the complexity of disqualifying offense analysis, facilities should consult employment counsel before making final termination decisions for any criminal records beyond clear-cut permanent disqualifying offenses.

Five-Year Re-Screening Requirements

Ohio regulations require nursing homes to conduct complete background checks for all employees at least once every five years. Re-screening follows identical procedures to initial employment screening including BCI&I and FBI fingerprint-based checks and database searches. The five-year clock begins from the initial background check completion date, not employment start date.

While RAPBACK enrollment provides continuous criminal activity monitoring, facilities should consult current ODH guidance and legal counsel to determine whether RAPBACK enrollment modifies five-year re-screening obligations. Regulatory interpretations continue evolving in this area. Until receiving definitive guidance specific to their circumstances, facilities should maintain five-year re-screening protocols for all employees regardless of RAPBACK enrollment status.

RAPBACK notifications trigger immediate investigation requirements when employees face new arrests or charges. Facilities should establish written procedures addressing how they'll respond to RAPBACK alerts, including immediate supervisory review, administrative leave pending charge resolution, and termination protocols if charges involve disqualifying offense categories. Employment counsel should review all response procedures.

When to Consult Employment Counsel

Background check compliance involves complex legal standards requiring specialized expertise that general guidance articles cannot provide for facility-specific circumstances. Employment law compliance demands professional legal analysis of individual circumstances, specific statutory provisions, and facility risk tolerance that generic guidance cannot address. The cost of legal counsel review represents modest investment compared to potential liability from wrongful hiring, FCRA violations, or inadequate resident protection measures.

Facilities should obtain legal review for the following situations:

  • Policy Development: All background check policies and conditional employment procedures require counsel review
  • Criminal Record Evaluation: Any criminal history beyond clear-cut disqualifying offenses needs legal analysis
  • Out-of-State Convictions: Substantially similar offense determinations require element-by-element comparison
  • FCRA Procedures: Adverse action processes must comply with federal statutory requirements
  • Report Disputes: Background check challenges and BCI&I correction procedures need legal guidance
  • RAPBACK Notifications: Real-time criminal activity alerts require immediate counsel consultation
  • Re-Screening Questions: Evolving regulatory interpretations about RAPBACK and five-year cycles need clarification
  • Resident Safety Incidents: Any incident involving conditionally employed workers demands immediate legal review

Facilities should establish relationships with employment counsel or healthcare compliance attorneys before compliance questions arise. This enables rapid consultation when urgent hiring decisions require legal analysis.

Vulnerable Population Protection Considerations

Nursing homes face heightened legal exposure due to resident vulnerability, with background check compliance representing minimum legal requirements rather than comprehensive risk management. Facilities remain responsible for resident safety and may face negligent hiring or retention claims even when following all regulatory requirements. Compliance with background check requirements does not eliminate liability for employee misconduct.

Facilities should consider maintaining lower risk tolerance than legally required minimums. This includes implementing robust supervision protocols exceeding minimum regulatory standards, maintaining comprehensive liability insurance covering employee misconduct, and documenting extraordinary care in all hiring decisions involving any criminal history. The vulnerable adult population in nursing homes deserves protection that goes beyond regulatory minimums.

Conclusion

Ohio nursing home background check requirements create a comprehensive compliance framework that facilities can navigate successfully through systematic processes and detailed documentation. The state's conditional employment provision offers valuable flexibility for addressing staffing needs while upholding resident protection through database screening, role-appropriate supervision, and expedited processing. Successful compliance demands clear understanding of the 40+ disqualifying offense categories under ORC 3721.121 requiring legal counsel analysis, meticulous tracking of dual-track BCI&I and FBI screening with strict FCRA adverse action compliance, and ongoing monitoring through RAPBACK enrollment and five-year re-screening cycles. By establishing robust protocols developed with employment counsel guidance and maintaining documentation demonstrating extraordinary care in protecting vulnerable residents, Ohio nursing homes can meet regulatory obligations while building qualified, trustworthy workforces dedicated to exceptional resident care.

Frequently Asked Questions

How quickly can Ohio nursing homes hire employees before background checks are completed?

Ohio nursing homes can hire employees immediately after conducting required ODH database checks within 48 hours of the employment start date. Conditionally employed workers must remain under role-appropriate supervision by fully screened employees until complete BCI&I and FBI background checks return with satisfactory results, typically within 1-4 weeks though processing may extend to 6 weeks or longer. Facilities should consult employment counsel to ensure supervision protocols meet regulatory standards for specific job classifications.

What crimes permanently disqualify individuals from Ohio nursing home employment?

ORC 3721.121 identifies numerous permanently disqualifying offenses including murder, rape, sexual battery, gross sexual imposition involving minors, kidnapping, patient abuse causing serious physical harm, and specific healthcare fraud offenses. The statute contains over 40 disqualifying offense categories with complex definitions and lookback periods that require legal analysis rather than reliance on general summaries. Facilities must consult employment counsel for evaluation of any criminal records, as proper disqualifying offense determination requires element-by-element statutory analysis.

Do Ohio nursing homes need both state and federal background checks?

Yes, Ohio regulations mandate dual-track screening combining BCI&I state criminal history checks with FBI federal background screening for all nursing home employees with resident access. BCI&I checks reveal only Ohio criminal activity, making FBI screening essential for identifying out-of-state offenses. Both screenings require fingerprint submission through approved channelers, with results typically processed within 1-4 weeks for straightforward cases, though complex multi-jurisdiction backgrounds may require 6+ weeks.

How much do Ohio nursing home background checks cost?

Complete Ohio nursing home employee screening typically costs $70-105 per candidate as of 2025, including fingerprinting services ($20-40), BCI&I state checks (approximately $35-50 including processing fees), and FBI federal screening (approximately $35-55 including channeler fees). Additional costs include database search services ($15-30 if using commercial vendors) and ongoing RAPBACK monitoring fees (approximately $2.50-3.00 per employee annually). Facilities should verify current pricing directly with BCI&I and approved channelers.

What is RAPBACK and why is it required for Ohio nursing home employees?

RAPBACK (Retention and Processing of Background Activity and Criminal Events) provides continuous monitoring that automatically notifies nursing homes when enrolled employees face new arrests, charges, or convictions anywhere in participating states. Ohio requires RAPBACK enrollment for all nursing home employees to enable real-time identification of emerging criminal activity rather than discovering offenses only during five-year re-screening cycles. Enrollment occurs automatically when facilities designate background check submissions as "retention" fingerprint checks.

How often must Ohio nursing homes re-screen existing employees?

Ohio nursing homes must conduct complete background checks for all employees at least once every five years, following identical procedures to initial employment screening including BCI&I and FBI fingerprint-based checks and database searches. While RAPBACK enrollment provides continuous criminal activity monitoring between cycles, facilities should consult current ODH guidance and legal counsel to determine whether RAPBACK enrollment modifies five-year re-screening obligations. Until receiving definitive guidance, facilities should maintain five-year re-screening protocols for all employees.

Can Ohio nursing homes hire individuals with old criminal convictions?

Employment eligibility depends on specific offense types and conviction dates, requiring legal counsel analysis rather than reliance on general guidance. Temporarily disqualifying offenses create employment bars extending 3-10 years from sentence completion (including probation and parole), after which candidates may become eligible. Permanently disqualifying offenses create lifetime employment bars regardless of time elapsed. Out-of-state convictions require element-by-element legal comparison to determine whether they constitute substantially similar offenses.

What FCRA procedures must nursing homes follow when background checks reveal disqualifying information?

FCRA requires strict adverse action procedures including pre-adverse action notice with complete background check report copy and FTC Summary of Consumer Rights, reasonable time for candidates to dispute accuracy (typically 5 business days though no federal minimum exists), and post-adverse action written notice including CRA contact information and dispute rights. During dispute periods, facilities should place workers on administrative leave without resident access. FCRA violations carry statutory penalties of $100-$1,000 per violation plus damages and attorney fees.

Additional Resources

  1. Ohio Department of Health Long-Term Care Facility Regulations
    https://odh.ohio.gov/know-our-programs/health-care-regulation/long-term-care-facilities
  2. Ohio Bureau of Criminal Investigation Background Check Services
    https://www.ohioattorneygeneral.gov/Business/Services-for-Business/WebCheck
  3. Ohio Revised Code Section 3721.121 - Employment Disqualifications
    https://codes.ohio.gov/ohio-revised-code/section-3721.121
  4. Ohio Nurse Aide Registry Search
    https://odh.ohio.gov/know-our-programs/nurse-aide-registry/nurse-aide-registry
  5. FBI RAPBACK Service Information
    https://www.fbi.gov/how-we-can-help-you/more-fbi-services-and-information/rap-back
  6. Office of Inspector General Exclusions Database (LEIE)
    https://oig.hhs.gov/exclusions/
  7. Fair Credit Reporting Act Compliance Guide for Employers
    https://www.ftc.gov/business-guidance/resources/using-consumer-reports-what-employers-need-know

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