Why continuous monitoring is becoming the standard for risk management in healthcare

Hospital staffing is defined by hiring sprints: You source a candidate, interview them, run a background check, verify their license, and if everything meets your requirements, you breathe a sigh of relief when they start their first shift. Traditionally, that was when concerns about an employee’s eligibility or background ended, until an annual license renewal or a random audit popped up. 

But circumstances change, licenses lapse, and potential risk can arise during the time between periodic checks. So “approved at the time of hire” is no longer sufficient to maintain ongoing risk mitigation or support your compliance efforts.  

Continuous monitoring closes the visibility gap created by periodic rescreens and helps you confirm that each person on your staff continues to meet your standards and stay eligible to provide care.  

Many healthcare organizations still rely on intermittent screening, like conducting annual rescreens and OIG Exclusion list or state license boards checks. This may meets the bare minimum of many requirements. But organizations may not be notified to any changes that occur between rescreens, which could expose them to potential patient safety, regulatory and financial risks.  

For example, employing excluded or sanctioned individuals can pose both a safety issue and a financial landmine. As of 2026, organizations that employ an excluded individual may be assessed civil monetary penalties (CMPs) of up to $25,595 for each item or service furnished by the excluded person for which Federal payment is sought, as well as assessments of up to three times the amount claimed for such items or services. The HIPAA Journal also notes that “six-figure civil monetary penalties are not uncommon and healthcare providers also run the risk of themselves being added to the HHS OIG Exclusions List.”  

The increase in travel nursing has made healthcare workers more mobile than ever. That can also creates additional screening gaps for providers.  

Continuous monitoring tools like Accurate‘ scan national databases in near real-time, catching “jurisdiction hopping”, or scenarios where someone frequently travels for work, that manual periodica checks may not report until long after the incident occurred. 

For Post-Acute and Acute care providers, Medicare and Medicaid reimbursements are the lifeblood of the business. Guidance from the Office of the Inspector General (OIG) states that if a facility is found to have an excluded person on the payroll, even in a non-clinical role like human resources or billing and accounting, their reimbursement stream could be at risk. 

The OIG maintains the List of Excluded Individuals and Entities (LEIE). The OIG guidance recommends that providers check the LEIE list at least monthly. As stated in the guidance cited above. “OIG updates the LEIE monthly, so screening employees and contractors each month best minimizes potential overpayment and CMP liability.” However, providers may choose their own search frequency.  

The OIG also recommends maintaining strict documentation of each search: “When checking the LEIE, providers should maintain documentation of the initial name search performed (such as a printed screen-shot showing the results of the name search) and any additional searches conducted, in order to verify results of potential name matches.”  

Conducting continuous monitoring through a third-party background check provider like Accurate can help you fulfill both of these needs: It can run ongoing checks against this list and create clear reports, all with less manual effort from your team.  

Timely identification of potential job-related issues can help support organizations in meeting their safety and compliance obligations.   

If a provider’s license is suspended due to an OIG investigation, or a job-related criminal conviction is added to their record, the appropriate team will receive an alert in near real-time, allowing them to respond more quickly and plan corrective action or remediation. 

To a long-time employee, a sudden switch to continuous monitoring may feel like a vote of no confidence. In an industry already plagued by burnout and high turnover, organizations can’t afford to make staff feel untrusted or surveilled. 

Implementing continuous monitoring with current staff requires intentional communication, honesty and an emphasis on proactive risk identification. Here is suggestions on how to do it well.

When announcing the shift to continuous monitoring, don’t frame it as a punitive measure to target “bad” employees. Frame it as a way to protect team integrity and uphold patient safety. 

Don’t hide information about your continuous monitoring program in the fine print of your employee handbook. Be upfront about it during the onboarding process. Explain that as a high-quality healthcare provider, the organization uses tools to monitor and verify each employee’s ongoing eligibility to practice. 

When people know what to expect from day one, your monitoring program feels like a standard operating procedure rather than a punishment or a show of distrust. 

Some organizations choose to maintain a self-reporting policy for license expirations, new sanctions, job-related criminal activity or other events that might impact an individual’s eligibility to practice. 

Continuous monitoring should complement this self-reporting policy, not replace it. So if you already maintain a self-reporting policy, continue to encourage employees to come to HR if they experience an event that could impact their continued job eligibility or their ability to meet your requirements..  

One potential strategy is to create a “grace period” policy. If an employee proactively self-discloses, HR may be able to work with them to take appropriate action.  

If the monitoring system reports it first and the employee stayed silent, the consequences may be more severe. This can build a culture of transparency and trust across your organization. 

Look for a continuous monitoring provider that offers the full range of healthcare-relevant monitoring services, in addition to criminal history searches. This may include:  

Also look for providers with industry-leading accuracy rates and self-service roster management to simplify monitoring. Also prioritize providers that push new alerts to your inbox the moment a change is found, rather than one that requires you to log in and “pull” a report.  

One of the most challenging parts of a continuous monitoring program is determining when and how to act on alerts.   

So before introducing your continuous monitoring policy, anticipate some of the alerts that might appear and, in partnership with your legal counsel, develop a response plan for each one.  

This should cover:  

Consider situations with different risk profiles — for instance, how you might respond to a conviction that has a direct nexus to the work being performed vs. a conviction without such a relationship. 

The intent shouldn’t be to pre-determine decisions, but to start a conversation about what a response plan might look like, anticipate pros and cons, and get alignment from all relevant stakeholders before actually receiving an alert.  

Continuous monitoring is no longer a “nice to have” for hospitals. It can be a fundamental tool for any healthcare organization that values patient safety, financial stability and a strong regulatory compliance program. 

Implementing continuous monitoring isn’t about a lack of trust in your employees. It’s about identifying and mitigating risk, and preventing visibility gaps into your workforce’s continued eligibility.