Background checks. As an employer, you know they’re important when hiring new employees. But what about existing employees? Should you just assume they’ll maintain a clean record once hired? That’s a risky bet these days. Situations change, and it’s crucial to stay on top of any incidents that could impact someone’s position. This is where continuous background monitoring comes in. 

Continuous monitoring means conducting periodic background checks on current employees to catch new red flags like criminal records, motor vehicle incidents, sanctions watchlists, and credential expirations. Rather than just screening at time of hire, ongoing monitoring allows you to stay continually updated on your workforce.

In this comprehensive guide, we’ll explore everything you need to know about continuous employee background screening and monitoring options. Whether you’re looking to strengthen compliance, reduce risks, or avoid negligence liability, implementing a robust continuous monitoring program is vital for any organization. Let’s dive in!

What is Continuous Background Monitoring?

Continuous background monitoring refers to regularly repeating background checks on existing employees at defined intervals. It involves screening for new issues that may emerge after the initial hiring. 

Typical components include:

– Criminal record searches

– Motor vehicle driving records  

– Credit reports

– Global sanctions watchlist screening

– Healthcare license monitoring

– Professional license/credential verification

The aim is to identify potential problems proactively so you can take appropriate action in a timely manner if needed. While a clear background check at hiring is crucial, it only gives a snapshot of that moment in time. Ongoing monitoring allows you to stay continually updated on your workforce.

Think of it as regularly changing the oil in your car. You don’t just do it once when you buy it and then never again. Regular maintenance and monitoring is key to long-term performance.

Why is Continuous Monitoring Important?

There are several compelling reasons ongoing background screening is essential:

Mitigate Business Risks

An employee involved in criminal activity, healthcare fraud, or global sanctions dealings can expose your business to significant liability and reputation risks. Continuous monitoring allows you to promptly identify issues before they escalate.

Strengthen Compliance 

Many regulated industries like healthcare, transportation, education, financial services have specific mandates to routinely screen employees. Active monitoring shows regulators you take compliance seriously.

Reduce Negligent Hiring Liability

Courts expect prudent employers to reasonably monitor staff over time. Robust screening programs demonstrate duty of care and help defend against negligence claims. 

Protect Brand Reputation 

If an employee commits a crime or violation, you could face major public backlash if it gets out you didn’t actively monitor personnel. Getting ahead of issues avoids Problems.

Enhance Workplace Safety

While rare, workplace violence is a reality. Ongoing background reviews can identify potential warning signs early so you can enact precautions.

Verify Ongoing Qualifications

Licenses, regulatory credentials, and memberships expire. Continuous verification ensures your team maintains appropriate qualifications.

In our transparent digital world, ongoing monitoring is no longer optional. One-time periodic checks are insufficient. Robust programs are becoming the norm as employers recognize their value.

Types of Background Checks to Monitor  

When conducting continuous screening, there are a variety of background check types to consider including:

Criminal Records 

Search county courthouses for new arrests, convictions, incarcerations, probation details based on current and previous addresses. Vital to catch local records.

Motor Vehicle Records

Check Department of Motor Vehicles in all states where an employee holds a license for new violations, accidents, and license status.

Credit Reports 

Monitor credit history for new bankruptcies, judgments, liens, collections which may indicate financial issues.

Global Sanctions

Screen international watchlists to verify no ties to embargoed countries, entities, or individuals. Critical for global business.

Healthcare Exclusions

Verify no Medicare/Medicaid exclusions or disciplinary actions against clinical licenses using national databases.

Professional Licenses

Confirm required licenses, certifications, and credentials are active and current through regulatory agencies.

The optimal mix of checks depends on the employee’s role and potential risks. Programs are tailored using relevant indicators for each position type.

Continuous Criminal Monitoring

One of the most common recurring background checks is a criminal record search. Typical checks include:

County-level Searches

Check courthouses in counties of residence to catch local cases not in statewide/national data. Core of any program.

Statewide Records

View cases across state courts for a statewide perspective. Helps find multi-jurisdiction offenses.

National Criminal Database 

Tap into criminal records from participating courts across the U.S. Useful supplement but can have gaps.

Federal Records

Cover district and appellate-level cases prosecuted at the federal vs. state level. Some charges start local then elevate.

Sex Offender Registries

Check national and local registries that those convicted of specific sex crimes must register with.

Global Watchlists 

Screen international agencies for potential terrorist, organized crime, or corruption associations.

For robust monitoring, county searches based on current + previous addresses are recommended together with supplemental state, national, federal, sex offender, and global database checks. This combo provides the most complete criminal coverage.

Continuous Motor Vehicle Records Monitoring

Since driving is important for many positions, monitoring the ongoing status of employee licenses and records is also vital. Typical checks include:

License Status

Confirm license is valid and current with no suspensions, revocations, or expirations.

Driving Violations

Flag new tickets, citations, infractions – speeding, reckless driving, DUIs etc. 

At-Fault Accidents 

Capture accidents where driver deemed partially or fully at-fault. Shows pattern of unsafe driving.

Driver Education

Check on status of any required new driver training courses.

Vehicle Registrations

Verify registration and insurance on personal vehicles used for work duties is active.

Regularly monitoring motor vehicle records allows you to catch concerning driving behaviors early so you can require training, suspend driving privileges, or take other actions as needed. This protects your business, employees, and the public.

Continuous Credit Monitoring 

Credit reports provide insight into an individual’s financial health and payment history. While employment credit checks require compliance with laws like the Fair Credit Reporting Act (FCRA), they can provide value:

Bankruptcies

Monitor for personal and business bankruptcy filings which may indicate financial distress.

Liens & Judgments

Tax liens can signal problems. Judgments show unpaid debts pursued through the courts.

Foreclosures / Repossessions

Signify large financial issues leading to home/asset loss.

Collection Accounts 

Unpaid medical bills and other debts gone to collection agencies.

Credit Inquiries

Numerous new applications over a short period can signal financial strains.

High Debt 

Balances exceeding thresholds of total available credit may be problematic.

Late Payments

Trends of late or missed payments signal problems managing obligations.

Regular credit checks can identify emerging employee problems early so financial counseling or other assistance can be offered before things escalate or impact job performance.

Continuous Global Sanctions Screening

Given expanding global business, monitoring for ties to embargoed countries, entities, and individuals is increasingly important. Typical listings include:

OFAC/SDNs

U.S. Office of Foreign Assets Control Specially Designated Nationals lists containing thousands of entities tied to sanctions targets like Iran, North Korea etc.

International Politically Exposed Persons

Heads of state, senior officials, and associates who may be corruption risks.

Narcotics Traffickers 

Significant foreign narcotics dealers targeted for U.S. trade restrictions.

Non-Cooperative Jurisdictions 

Countries with deficiencies in anti-money laundering/terrorism financing protections.

EU and UN Sanctions

European Union and United Nations listings of prohibited global dealings.

International Wanted Lists

Notices from Interpol, regional agencies of fugitives sought for financial crimes, money laundering, and terrorism.

Given the heavy penalties and brand damage that can result from sanctions violations or prohibited transactions, ongoing screening is crucial for risk mitigation and compliance.

Continuous Healthcare Exclusion Monitoring 

For healthcare providers, routinely monitoring federal and state exclusion/debarment lists and licensing boards is imperative:

Medicare/Medicaid Excluded

Check for exclusions from government programs for fraud, abuse, or other issues.

GSA Debarments 

The General Services Administration (GSA) debars individuals/entities from federal contracts including healthcare.

FDA Debarments

Bars participation in drug/device development, clinical trials for prior violations.

License Discipline

Monitor state licensing boards for restrictions, probation, suspensions, or revocations.  

DEA Registrations

Confirm DEA approval to prescribe controlled substances is intact.

Medical Board Actions

Watch for quality of care complaints, malpractice, and other disciplinary actions.

Regular screening for licensure actions and program exclusions is imperative to avoid penalties and protect patient safety by identifying problematic practitioners early.

Continuous Professional License Monitoring

Ongoing verification of required licenses, certifications and credentials is key since they periodically expire and face potential disciplinary issues. Checks to consider:

License/Certification Status

Confirm any licenses, certs tied to one’s position remain active and current with no restrictions.

Renewal Applications 

Monitor for background questions on renewals that can contain self-disclosed problems not found elsewhere.

Continuing Education

Verify any mandated continuing education credits are completed.

Firm/Practice Credentials

Ensure business licenses, regulatory approvals, and facility credentials are maintained.

Board Certifications

Recheck professional designations like CPA, CFA, etc. have not lapsed.

Documenting employees maintain proper qualifications reduces compliance risks and liability while ensuring competencies stay up-to-date.

What Should You Monitor Continuously?

When building an ongoing monitoring program, focus on checks relevant to each employee’s role and risk factors:

High Risk Roles

Prioritize frequent monitoring for positions with elevated fraud, safety, compliance or security exposures.

Licensed Positions 

Closely verify critical licenses/credentials stay current and valid.

Driving Exposure

Monitor motor vehicle records more frequently for those driving regularly. Monthly or quarterly are common.

Financial Access

Watch credit reports and global sanctions lists for those in accounting, finance, banking etc.

Sensitive Data Access

Closely monitor criminal records, credentials and global sanctions for those with data access.

Client Interaction  

More frequent reviews of customer-facing staff, especially those serving vulnerable groups.

Previous Issues

Watch known areas of prior concern like a past criminal record more closely.

Matching monitoring frequency and check types to specific job risks and exposures strengthens program effectiveness and efficiency.

How Often to Conduct Monitoring

A big question is how frequently should screening be repeated? Consider several factors:

Industry Standards 

Some sectors like healthcare, transportation set mandatory intervals such as checking nurse credentials quarterly.

State Laws 

A growing number of states mandate periodic monitoring such as checking educational roles annually.

Business Needs

Tailor frequencies based on risk tolerance, liability concerns, and sensitive job types. Quarterly to annually are common.

Check Type

Attributes that change frequently like driving warrant more regular refreshes. Criminal records may need only annual.

Client Requirements

Some partners/customers want employee re-verification at specific intervals to maintain relationships.

Cost Considerations 

If paying per check, overall program cost influences frequency. Lower cost enables more frequent updating. 

Implementation Resources 

Available staff time to manage logistics impacts feasible schedule. Look for automation to assist.

While no one-size-fits all standard exists, annual monitoring is a typical starting point with higher risk indicators checked more frequently. State laws and client contracts may also dictate required intervals.

Benefits of Continuous Monitoring

There are many advantages continuous screening provides versus periodic one-time checks:

Early Detection

Identify issues proactively in a timely manner before they escalate

Demonstrates Due Diligence 

Shows regulators and courts you reasonably monitor workforce over time. Strengthens compliance defenses and reduces liability risks.

Adheres to Legal Mandates

Satisfies industry-specific laws requiring recurring background reviews.

Enhances Workplace Safety 

Timely identification of potential warning signs enables precautions and proactive interventions.

Verifies Ongoing Qualifications

Confirms licenses, credentials remain current and in good standing. 

Deters Bad Behavior

Employees know they are being monitored which discourages problems.

Reduces Risks

Allows removal or assignment change of personnel that develop issues or unacceptable risks.

Provides Ongoing Assurance

Comfort that workforce continues to meet background check standards over time.

The benefits of continuous monitoring are clear. It brings awareness of changes in real-time rather than after the fact.

Limitations of Periodic Monitoring

While once common, infrequent or only periodic monitoring has distinct drawbacks:

Delayed Detection

Annual or longer lags between checks allow issues to go unnoticed.

Renewal Cycles Missed

Expired licenses, credentials unchecked until next update which can create compliance fractures.

Application Disclosures Missed 

Self-reported disciplinary or criminal matters on license renewals not identified in real-time.

Higher Negligence Risks

Lack of demonstrated ongoing due diligence makes liability claims more likely.

Potential Legal Violations  

May fail to meet mandated monitoring laws for high risk roles.

Workforce Risks

Problematic employees remain in place between checks. Safety and security threats unidentified.

Lagging Remediation 

Delays ability to swiftly respond with additional training, job reassignment or termination.

False Security

Periodic snapshots provide minimal assurance of workforce integrity and qualifications.

Wise employers recognize robust continuous monitoring is superior to limited periodic checking.

Options for Implementing Monitoring

There are several ways to implement continuous screening:

Outsource to a Firm

Hire a professional screening provider to handle program end-to-end. Efficient “one stop” but vet partner carefully.

Leverage Applicant Tracking Systems

Some ATS platforms offer basic built-in monitoring modules but functionality can be limited.

Build In-House Program 

Use internal HR staff to manually conduct checks on courts, databases, and verification sources. More work but adds control.

Get End-to-End Software

Robust SaaS systems automate monitoring processes. Powerful but require budget.

Hybrid Approach  

Blend options such as outsourced help for global scanning, in-house system for domestic monitoring. Provides balance.

Evaluate resources, risks, control preferences, and costs to choose optimal approach.

Choosing a Continuous Monitoring Partner

If outsourcing screening to an external party, considerations when selecting a partner include:

Comprehensive Checks

Look for wide range of monitoring options – criminal, MVRs, sanctions, credentials etc.

Global Reach 

Can they screen worldwide locations where your company operates?

Automation

Seek robust scheduling, notifications, and workflow capabilities.

Compliance

Ensure adherence with FCRA, GDPR, data security standards. Ask for specifics.

Configurability

Ability to tailor packages by job types, locations, frequencies etc. 

Court Coverage

Check sources used to confirm quality data with few gaps.

Client Service

Resources to assist with implementation, case management, and training. 

Pricing

Per check fees add up. Seek economy of scale for monitoring programs.

Technology Integration

Do they integrate with your HRIS, ATS, and other systems?

Vetting capabilities, global coverage, compliance, court data, and service models allows you to choose the ideal partner to meet program objectives within budget.

Implementing a Monitoring Program

Key steps to roll out continuous background screening include:

Set Objectives

Document goals, acceptable risks, legal requirements, and priority job types. Get executive buy-in.

Establish Criteria

Choose checks required, frequencies, and monitoring processes by location and role.

Select Technology 

Assess options for automated systems, tool integrations, and reporting capabilities.

Partner with Vendors

If outsourcing, research and select provider(s) that align with program needs and resources.

Configure Program  

Work with partners/vendors to tailor packages, systems, and parameters.

Communicate Expectations

Inform staff of new program through training, handbooks, signage, and acknowledgements.

Phase-in Monitoring

Start with highest risk roles first. Expand to wider workforce over time.

Refine Processes 

Monitor early rollout and adjust frequencies, checks, tools, and procedures as warranted.

Continuously screening existing staff is a journey requiring planning, partnerships, and adjustment along the way. Set goals but recognize programs evolve.