Healthcare Compliance

FACIS Level 3 Healthcare Sanctions Screening

The most comprehensive healthcare exclusion screening available. Search 2,000+ federal and state sanctions sources to protect your organization and patients.

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What Is FACIS Level 3?

FACIS (Fraud and Abuse Control Information System) Level 3 is the most thorough healthcare exclusion screening available. It searches over 2,000 federal and state sanctions sources, disciplinary actions, and exclusion lists to determine whether an individual has been sanctioned or excluded by a healthcare regulatory body.

Organizations participating in Medicare, Medicaid, or other federal healthcare programs are required to screen employees and contractors against the OIG exclusion list. FACIS Level 3 goes beyond the basic OIG/SAM check.

Screening Levels Compared

Level 1 – Basic
OIG and GSA/SAM exclusion lists only
Level 2 – Standard
Level 1 plus FDA debarment, DEA, and state Medicaid
Level 3 – Comprehensive
All Level 2 plus 2,000+ state licensing boards and regulatory sanctions

Who Needs FACIS Level 3?

Hospitals & Health Systems
Credentialing and compliance
Home Health & Hospice
CMS conditions of participation
Nursing Facilities
Federal certification requirements
Behavioral Health
Licensing and accreditation
Pharma & Medical Devices
Vendor compliance programs
Any Medicare/Medicaid Biller
Required for federal program participation

How the FACIS Level 3 Screening Process Works

Catapult handles every step of the FACIS screening process — from ordering through results delivery — so your compliance team can focus on decisions, not logistics.

1
Submit Your Order

Provide the subject’s name, date of birth, and address history. Catapult’s secure portal accepts individual or batch orders with role-based access controls for your credentialing team.

2
FCRA-Compliant Consent

For employment screening, proper applicant authorization is obtained in accordance with the Fair Credit Reporting Act. Our process includes compliant disclosure forms and authorization documents designed to protect your organization.

3
Comprehensive Database Search

Catapult simultaneously queries 2,000+ federal and state exclusion sources — including OIG, GSA/SAM, FDA debarment, DEA, all 50 state Medicaid exclusion lists, state licensing board disciplinary records, and additional regulatory sanctions databases.

4
Adjudication and Reporting

Results are returned with clear pass/match/review flags. Positive hits include the source database, exclusion type, and effective dates. Our team is available to assist with ambiguous matches — including common name disambiguation and identity verification.

5
Documentation and Recordkeeping

Results are stored in your secure portal for audit readiness. CMS, OIG, and accreditation bodies expect documented evidence of screening — Catapult’s reports are formatted for immediate use in your compliance files and credentialing packets.

What Sources Does a FACIS Level 3 Report Search?

FACIS Level 3 is the only healthcare screening that searches all of the following in a single report. Each source category represents a distinct regulatory risk area.

Federal Exclusion Lists
  • OIG List of Excluded Individuals/Entities (LEIE)
  • GSA System for Award Management (SAM)
  • Tricare Exclusion List
Federal Regulatory Bodies
  • FDA Debarment List
  • DEA Controlled Substances
  • EPLS / Federal Civil Actions
State Medicaid Exclusions
  • All 50 state Medicaid exclusion lists
  • State agency fraud alerts
  • State program integrity units
State Licensing Boards
  • Physician and nursing boards
  • Pharmacy, dental, and PT boards
  • Social work and behavioral health
Disciplinary Actions
  • License revocations and suspensions
  • Probations and restrictions
  • Consent orders and reprimands
Additional Sanctions
  • Civil monetary penalties (CMPs)
  • Corporate integrity agreement lookups
  • Healthcare-specific debarment records

OIG Check vs. FACIS Level 3: What’s the Difference?

Many organizations check only the OIG LEIE and SAM databases and believe they’ve met their compliance obligations. That leaves significant exposure. FACIS Level 3 covers sources that a basic OIG check misses entirely.

A healthcare worker can be excluded from a state Medicaid program or have their professional license revoked by a state board — and still pass an OIG-only check. FACIS Level 3 surfaces these records because it reaches into the 2,000+ sources the federal lists don’t touch.

For organizations subject to CMS Conditions of Participation, Joint Commission standards, or NCQA accreditation, FACIS Level 3 is the recognized standard for meeting exclusion screening obligations.

Data Source
OIG Only
FACIS L3
OIG / SAM✓✓
FDA Debarment✗✓
State Medicaid Exclusions✗✓
State Licensing Boards✗✓
License Revocations✗✓
Civil Monetary Penalties✗✓

How Often Should You Run FACIS Screening?

A point-in-time FACIS check at hire is not sufficient for ongoing compliance. An employee or vendor can be sanctioned at any time — and you won’t know unless you check again.

At Hire
Pre-Employment Screening

Required before any individual begins providing services that could be billed to federal healthcare programs. CMS guidance requires this for all new hires and contractors.

Monthly
Monthly Re-Screening

OIG guidance recommends monthly re-screening of all current employees and contractors. The OIG updates its exclusion list monthly — and your organization can be held liable for payments made during any month an excluded individual was active.

As Needed
Credentialing Re-Verification

Joint Commission and NCQA standards require re-credentialing every two years. Many healthcare systems run a full FACIS Level 3 check at each credentialing cycle as part of their privileging documentation.

FACIS Level 3 Frequently Asked Questions

What is a FACIS background check?

A FACIS (Fraud and Abuse Control Information System) background check is a specialized healthcare exclusion screening that searches federal and state databases to determine whether an individual has been sanctioned, excluded, or debarred from participation in Medicare, Medicaid, or other government healthcare programs. FACIS Level 3 is the most comprehensive version, searching over 2,000 sources including all 50 state Medicaid exclusion lists and state professional licensing board records.

Who is legally required to perform FACIS screening?

Any organization that receives reimbursement from Medicare or Medicaid is required to screen employees and contractors against the OIG LEIE. This includes hospitals, physician practices, home health agencies, nursing facilities, behavioral health providers, pharmacies, durable medical equipment suppliers, and any entity billing federal healthcare programs. Many accreditation bodies — including The Joint Commission and NCQA — specify FACIS Level 3 as the standard for meeting these obligations.

What is the difference between FACIS Level 1, 2, and 3?

FACIS Level 1 searches only the OIG and GSA/SAM exclusion lists. FACIS Level 2 adds FDA debarment, DEA, and state Medicaid exclusion databases. FACIS Level 3 includes everything in Level 2 plus all 50 state professional licensing board records, disciplinary actions, license revocations, consent orders, and additional regulatory sanctions. For organizations credentialing clinical staff or subject to CMS oversight, Level 3 is the appropriate standard.

How long does a FACIS Level 3 check take?

Most FACIS Level 3 results are returned within one to two business days. Because FACIS searches proprietary compiled databases rather than manually contacting each source, turnaround is fast — typically faster than a standard criminal background check that requires court record retrieval. Rush processing is available for urgent credentialing situations.

Can FACIS screening be used for vendor and contractor compliance?

Yes. OIG guidance makes clear that exclusion screening obligations extend to independent contractors, vendors, and any individual whose services may be billed to federal healthcare programs — not just W-2 employees. Many organizations run FACIS Level 3 on all healthcare staffing agency employees, locum tenens physicians, therapy contractors, and managed care vendors as part of their ongoing compliance program.

What happens if I employ someone who is excluded?

Employing an OIG-excluded individual and billing federal programs for their services can result in civil monetary penalties of up to $20,000 per item or service, plus three times the amount claimed, plus program exclusion for your organization. The OIG does not consider good-faith mistakes as a defense if the employer failed to screen — which is why documented monthly re-screening is essential.

Is FACIS screening an FCRA consumer report?

FACIS screening conducted for employment purposes is governed by the Fair Credit Reporting Act (FCRA). This means proper disclosure and authorization must be obtained before ordering a FACIS check for an applicant or employee, and adverse action procedures must be followed if the results affect an employment decision. Catapult’s process includes FCRA-compliant forms and workflows to protect your organization and the subject of the report.

Does Catapult offer ongoing monthly FACIS monitoring?

Yes. Catapult offers automated monthly re-screening programs that run your entire employee and contractor roster against updated exclusion databases each month. You receive exception reports only when a new exclusion or disciplinary action is detected — eliminating manual tracking while maintaining the documented compliance history that auditors and accreditation bodies expect.

Run a FACIS Level 3 Screen

Catapult manages your healthcare sanctions screening from enrollment to results.

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PBSA - Professional Background Screening Association
PBSA Member
Catapult is a proud member of the Professional Background Screening Association, upholding the highest standards of accuracy, compliance, and consumer protection in background screening.

*Catapult Services Corporation is an investigative agency licensed by the Private Protective Services Board of the State of North Carolina specializing in corporate pre-employment background screening. Our corporate agency license is BPN 001473P11M, Qualify Agent, Kevin von der Lippe, PI, 2891. Catapult Services Corporation is a consumer reporting agency that supplies applicant screening services for employment, volunteer and student screening, to authorized organizations under the conditions of the federal Fair Credit Reporting Act.

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Personal Information Disclosure: United States or Overseas

Personal information submitted to Catapult Services Corporation for background screening is not transferred to third parties outside of the United States or its territories unless the completion of a background report about the person requires gathering information about that person from outside the United States (ex. international criminal check, verification of employment records outside the United States or verification of education records outside the United States.) All personal information will be transmitted and stored in a secure manner in accordance with the terms of this Privacy Policy.