The Basics

Standard requires that your organization conducts an employment background check for employees who handle pharmaceuticals and patient data.  In a response to a request for interpretation, URAC has stated that criminal background checks are required for every employee who handles patient data and drug testing/screening is required for every employee who handles pharmaceuticals.

The criminal background check must include a minimum identification check, criminal history, a record as a sex offender, and other relevant information.  The drug testing and screening that is contemplated by the standard should not be limited to illegal drugs.  This is a consumer safety issue, so any substance abuse issue that could affect consumer safety, including alcohol abuse, is within the scope of the standard.

Management Tips

Your policies and procedures should not only address the two elements of this standard, i.e., background check and drug check, which also include mechanisms for taking corrective action in case the organization's substance abuse policy is violated.  The policies and procedures also should include a discussion as to how your employees will be trained regarding your screening programs.  Finally, your program should have a mechanism of recording consumer complaints regarding violations of access to personal information of the consumer.

One question has been whether this is required of all employees who come in contact with drugs and/or patient records or only new hires. While the standard is not clear on this subject, none of the interpretive information we have seen would suggest that you can limit this to new hires. The frequency with which you do this, once you've done it, is certainly up to you, however. 

URAC Accreditation Tips

Both of the elements of the standard are mandatory.

For the desktop review, submit your conference of policies and procedures regarding background checks, substance abuse, and training.

During on-site review, the reviewer will examine a log of consumer complaints in search of evidence that you handle complaints about personal information violations appropriately.  Be prepared to produce evidence that, where such a complaint has been lodged, your organization has taken appropriate corrective action.