Protecting Your Workforce Through Post-Employment Screening

A background check is not the finish line—it’s the starting point for managing employee risk.

When an employee is hired, organizations often feel confident knowing a background check was completed. But a pre-employment background check is only a snapshot in time. The day after an employee starts, circumstances can change—and your organization may never know unless you have a process to check again.

An employee could receive a DUI, be charged with theft, lose a professional license, appear on a federal exclusion list, receive serious traffic citations, or become involved in another reportable event. Previous records can also be updated by the courts after the original background check is completed.

That is why more organizations are looking beyond the initial background check and developing post-employment screening programs.

Why Employee Risk Doesn’t End After Hire

Hiring someone is an important risk-management decision, but the risk doesn’t necessarily end once the employee walks through the door.

Depending on your industry and workforce, changes in an employee’s record could contribute to:

• Negligent retention claims
• Workplace violence concerns
• Increased insurance costs
• Regulatory penalties
• DOT and fleet liability
• Patient safety concerns
• Damage to your organization’s reputation

The important question for employers is simple:

When was the last time every employee was re-screened?

For organizations with large workforces, employees in safety-sensitive positions, or employees who work with vulnerable populations, having a defined post-employment screening strategy can provide an additional layer of protection.

Industries That Can Benefit From Post-Employment Screening

Post-employment screening can provide value across many industries, particularly where employees are entrusted with customers, patients, financial assets, vehicles, sensitive information, or other responsibilities.

Industries identified in our webinar include:

• Healthcare
• Transportation
• Manufacturing
• Financial services
• Education
• Government contractors
• Staffing
• Nonprofits
• Hospitality
• Organizations with fleet drivers

Ultimately, any organization placing significant trust in its employees can benefit from having a process for monitoring changing risk.

Two Approaches to Post-Employment Screening

There are two primary approaches organizations can use: periodic employee re-screening and continuous risk monitoring.

1. Periodic Employee Re-Screening

With periodic re-screening, employers establish a schedule for checking employees again. Depending on the organization’s needs, screening may occur:

• Quarterly
• Semi-annually
• Annually
• Every two or three years
• Upon promotion or another change in job responsibilities

RSI’s portal can also be used to automatically flag employees for future re-screening, and screening packages can be customized based on the organization’s needs.

Periodic re-screening can be a simple and lower-cost approach. However, there is an important limitation: risk can develop between screenings.

2. Continuous Risk Monitoring

Continuous Risk Monitoring takes a different approach.

Instead of waiting for the next scheduled re-screen, employee activity is monitored continuously and alerts can be generated when reportable activity occurs. This gives employers earlier awareness of potential issues and can reduce organizational exposure.

For many organizations, the best strategy isn’t choosing one approach over the other. Periodic re-screening and continuous monitoring can work together as part of a comprehensive post-employment screening program.

What Can Continuous Criminal Monitoring Identify?

RSI’s Continuous Criminal Monitoring can monitor for new criminal activity, including:

• Violent crimes and assault offenses
• Theft, fraud and forgery offenses
• Drug-related offenses
• Weapons offenses
• Domestic violence-related offenses
• Offenses involving minors
• Sex-related offenses
• Corruption and breach-of-trust offenses
• Criminal ordinance violations
• General criminal court filings
• Noncompliance and contempt-related offenses

The goal isn’t simply to generate alerts. The process is designed to identify potentially reportable activity and then verify the information before it is delivered to the client.

Traffic Monitoring Can Be Critical for More Than Drivers

Traffic monitoring isn’t limited to traditional transportation companies.

It can be particularly valuable for organizations with:

• Company drivers
• Sales staff
• Healthcare employees
• Delivery personnel
• Executives
• Fleet vehicles

RSI Traffic Monitoring can identify serious traffic offenses, DUI/DWI activity, reckless driving, speeding over 25 MPH, driving while suspended or revoked, and hit-and-run activity.

There is an important distinction: traffic monitoring is based on court-reported traffic activity and does not include administrative MVR actions such as license suspensions, revocations, CDL downgrades, or license-status changes. However, underlying traffic offenses that may lead to those administrative actions can be identified through ongoing monitoring.

Healthcare Organizations Have Additional Monitoring Needs

Healthcare organizations face unique compliance and patient-safety considerations.

Healthcare Monitoring can include checks involving:

• OIG — Office of Inspector General
• LEIE — List of Excluded Individuals and Entities
• DEA — Drug Enforcement Administration
• SAM — System for Award Management
• Tri-Care
• State Medicaid lists
• Board actions
• Professional license status

For organizations subject to healthcare compliance requirements, these types of checks can provide an important layer of ongoing oversight.

How Continuous Risk Monitoring Works

A post-employment monitoring program doesn’t have to be complicated.

The RSI process follows four basic steps:

1. Employee Enrollment
Organizations can upload an employee roster or automatically flag employees for monitoring when the original background check is ordered.

2. Initial Lookback Review
Criminal and traffic monitoring can include a three- or six-month lookback.

3. Continuous Monitoring
The employee remains enrolled for ongoing monitoring.

4. Alert Notification
When potentially reportable activity is identified, RSI reviews and verifies the information. Additional county criminal, MVR, or medical/exclusion searches may be completed when needed before an alert is reported.

This process is designed to make post-employment screening easier to incorporate into an organization’s existing hiring workflow.

Enrollment Can Fit Your Existing Hiring Process

Organizations can choose how employees are added to monitoring.

RSI offers:

• Automatic enrollment when the original background check is ordered
• Batch uploads of employee rosters
• Monthly additions
• Immediate employee removals

The objective is simple: RSI adapts to your hiring process—not the other way around.

What Happens When an Alert Is Generated?

A monitoring alert isn’t simply passed directly to an employer.

The RSI process includes verification before the client is notified:

Monitoring hit → RSI verification → Additional search if needed → FCRA review → Client Portal alert → Employer review

Depending on the circumstances, RSI may complete an additional county criminal search, MVR, or MedEx search before reporting the information. RSI verifies reportable information before notifying clients, while the employer ultimately reviews the information according to its own internal policies.

This verification process is an important part of responsible post-employment screening.

An Important Expectation: Monitoring Isn’t Instant

Continuous monitoring does not mean every event will appear immediately.

Court systems update at different speeds. Some report daily, while others may take weeks. Monitoring alerts are therefore timely based on the availability and timing of court reporting.

This is an important distinction for employers to understand when establishing expectations for any monitoring program.

Build a Post-Employment Screening Strategy Around Risk

Not every employee necessarily requires the same level of screening.

Organizations can customize their approach based on:

• Employee role
• Risk level
• Department
• Regulatory requirements
• Driving responsibilities
• Access to vulnerable populations
• Healthcare responsibilities

For some employees, annual re-screening may be appropriate. For higher-risk positions, continuous criminal, traffic, or healthcare monitoring may provide an additional layer of protection.

The key is to move from a one-time screening mindset to an ongoing risk-management strategy.

The Bottom Line

A pre-employment background check tells you about an applicant’s history at the time the search is conducted. It cannot tell you what may happen six months or two years later.

That’s why post-employment screening deserves a place in your organization’s risk-management strategy.

A comprehensive program can combine periodic re-screening with Continuous Risk Monitoring to help identify new criminal, traffic, and healthcare-related issues. RSI offers flexible solutions that can be customized by employee role, risk level, or department, with automated enrollment, batch uploads, Client Portal alerts, and an FCRA-compliant review process.

The goal isn’t to assume that employees will create risk. It’s to make sure your organization has a process for identifying changing risk when it does occur.

A proactive post-employment screening program demonstrates your organization’s commitment to safety, compliance, and protecting employees, customers, and your reputation.

The information presented in this article is for educational purposes only and is based on current practice, industry-related knowledge, and business expertise. It is not intended to constitute legal advice.

Reference Services, Inc.
Accurate Data / Fast Results / Real People

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PDF copy of our presentation here:  Q3 Compliance Update – Beyond the Background Check – Reducing Employer Risk Through Post-Employment Screening

Reference Services, Inc. is dedicated to ensuring client satisfaction by delivering exceptional customer service. Our U.S.-based team offers solutions designed to help clients build a safe, productive, and dependable workforce, utilizing cutting-edge technology. With our expertise and experience, RSI provides swift and precise reports at an unmatched value.

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