And, because the background investigation is often the last safeguard before allowing the applicant to become an employee, it has to be done right.
Hundreds of companies call on Imperative to research the backgrounds of prospective and current employees. We work with each client to identify the information requirements unique to their business priorities and then meet those requirements within legal and ethical guidelines.
While we work with many clients to create custom packages to meet their needs, the following table outlines the content of our more common background investigation packages:
Common Background Investigation Packages
|Identity Validation (additional options)|
|Basic Identity Research||⊕||⊕||⊕||⊕||⊕||⊕||⊕|
|Criminal History Research (additional information)|
|Multi-jurisdictional Criminal Database Review||⊕||⊕||⊕||⊕||⊕||⊕||⊕|
|County-level Criminal Records Searches||⊕||⊕||⊕||⊕||⊕||⊕||⊕ *|
| State-level Criminal and Sex Offender Records Searches ||⊖||⊕||⊕||⊕||⊕||⊕||⊖|
| Federal District Criminal Records Searches ||⊖||⊕||⊕||⊕||⊕||⊕||⊖|
|Driving and Safety History (additional options)|
|Standard Driving History||⊖||⊖||⊕||⊕||⊕||⊕||⊖|
| Commercial Driver’s License Information System (CDLIS)||⊖||⊖||⊖||⊖||⊖||⊕||⊖|
| Driver Safety Performance and Substance Abuse History ||⊖||⊖||⊖||⊖||⊖||⊕||⊖|
| FMCSA Pre-Employment Screening Program (PSP)||⊖||⊖||⊖||⊖||⊖||⊕||⊖|
|Credentials and Experience Verification|
| Employment Verifications ||⊖||⊖||⊕||⊕||⊕||⊕||⊖|
| Education Verification ||⊖||⊖||⊕||⊕||⊕||⊖||⊖|
| License & Certification Verification ||⊖||⊖||⊖||⊕||⊕||⊖||⊖|
|Civil Litigation History|
| County Civil Litigation Searches ||⊖||⊖||⊖||⊕||⊖||⊖||⊖|
| Federal District Litigation Searches ||⊖||⊖||⊖||⊕||⊖||⊖||⊖|
|Healthcare Exclusions Research|
| Federal & State Healthcare Fraud Exclusion Lists ||⊖||⊖||⊖||⊖||⊕||⊖||⊖|
| ⊕ Default ||⊖ Optional ||* Search of county of residence only|
Civil Litigation History
County Civil Litigation – This review of civil litigation in all counties and under all names associated with the applicant’s identity research in the last ten years. Each search will cover a minimum of ten years of plaintiff and defendant records in that jurisdiction – most will cover much longer periods.
Federal Civil Litigation – This review of civil litigation in each federal district associated with the applicant in the last ten years will identify federal lawsuits and bankruptcies associated with your candidate. Each search will cover a minimum of ten years of plaintiff and defendant records in that jurisdiction – most will cover much longer periods.
Civil Case Copy Retrieval – It is often desirable to retrieve copies of documents from court files to better understand the issues leading to litigation, claims made by the parties, details of settlement agreements, or develop additional information about the parties to the case.
Credentials and Experience Verification
Employment Verification – We will diligently attempt to verify directly with a former supervisor, Human Resources department, or other authorized source the current and previous employment claims made by your applicant. Unless otherwise indicated, our standard packages include three current or prior employers. However, additional verifications can be added on request.
Education Verification – We will attempt to verify college, university, or trade school accomplishments asserted by your applicant, watching out for unaccredited institutions and degree mills. Unless otherwise indicated, our standard packages include the highest-level of degree actually achieved. However, additional verifications can be added on request.
License and Certification Verification – We will attempt to verify the license or certification claims made by your applicant.
Income Tax Return Verification – Upon completion of an IRS Form 4506T by the applicant, Imperative can retrieve prior years’ tax returns and wage statements (W-2s and 1009s). This is very useful for verifying prior wages during income negotiations or verifying applicants’ claims of self-employment.
Consumer Credit Reports – Credit reports can be a useful tool for evaluating an individual for employment when one’s management of one’s personal business affairs may be reflective of how the individual may manage the business affairs of the employer.
The credit report will reflect the details of the individual’s credit accounts, including balances and payment history. It will also reflect any accounts that are past due or in collection.
Imperative believes that it is important to highlight, however, that the few published studies on the use of credit reports in predicting either integrity or future job performance suggest that there is no correlation. Imperative recommends review of credit reports primarily when the individual will be making financial decisions affecting the employer or company clients.
Professional or Personal References – We will conduct interviews with individuals familiar with your subject, focusing on their honesty and integrity, behavior and interpersonal skills, and general reputation. These start with references provided by your applicant. Because these individuals are typically notified by the applicant that such contact may be made, security-conscious employers often request that we develop additional references through those named by the applicant.
Corporate Affiliations Search – We will search private databases and the records of the state Secretaries of State for business entities currently or previously associated with your subject. As a follow up, clients may request additional research into the civil litigation histories of any entities found.
Healthcare Sanctions Search – Employers receiving state or federal funds are prohibited from employing individuals listed as having participated in healthcare fraud or other kinds of disqualifying activities. Our expansive database search includes searches of dozens of federal and state exclusion lists, including these most-requested items:
State Healthcare Fraud Exclusions List –The Texas Health & Human Services Commission Office of Inspector General (OIG)’s Exclusions List (or equivalent lists for residents of other states).
Federal Healthcare Fraud Exclusions List – The US Department of Health and Human Services OIG’s List of Excluded Individuals and Entities.
Federal Procurement Exclusions List – The System for Award Management (SAM – previously called EPLS), which includes the General Services Administration’s list of individuals prohibited from participating in a variety of federal procurement programs and other forms of commerce. This system also includes the Office of Foreign Asset Control’s (OFAC) Specially Designated Nationals list.
USA PATRIOT Act and Financial Compliance Search – This regularly updated database search includes a search for enforcement actions and orders by dozens of regulatory institutions, including the Federal Financial Institutions Examination Council (FFEIC) institutions [the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS)], as well as a search for individuals listed in the System for Award Management (SAM – previously called EPLS), which lists individuals prohibited from participating in a variety of government procurement programs, as well as regulated medical, financial, and international transactions.
FINRA Compliance Package – Effective July 1, 2015, The SEC approved FINRA’s proposed rule change to adopt NASD Rule 3010(e) (Qualifications Investigated) relating to background checks on registration applicants as FINRA Rule 3110(e) (Responsibility of Member to Investigate Applicants for Registration). This rule includes new provisions relating to the verification of information in the Form U4 (Uniform Application for Securities Industry Registration or Transfer). Imperative can work with broker-dealers to ensure compliance with this rule and improve the quality of all hires.