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Healthcare Staffing Credentialing Checklist: Before the First Shift

Every facility sends its own list. Most ask for the same core items: proof of license, exclusion checks, a background check, health records, life support cards, competency proof, and orientation. This checklist shows what agencies typically keep for each worker before a first shift. It also marks where each item comes from: federal law that applies to your agency, federal rules that apply to the facility, accreditor expectations, or common practice.

Updated October 3, 2026 · Checked against the official sources listed at the end

Where the requirements come from

It helps to sort each item by who requires it. That tells you what is fixed and what you can negotiate in a contract.

Some federal laws apply to your agency as the employer, such as Form I-9 and, when you use a background check company, the Fair Credit Reporting Act (FCRA). Other federal rules apply to the facility, such as Medicare's rules for hospitals and nursing homes. Facilities pass those duties to you through contracts. Accreditors such as The Joint Commission add their own expectations. Everything else is common practice or client preference.

License, certification, and primary source verification

Verify every required license or certification with the issuing source, not from a copy. Joint Commission says a copy of a license, in place of proof that primary source verification was done, does not meet the intent of its requirement. Its hospital requirements call for this check at hire and at renewal. For nurses, NCSBN's free Nursys QuickConfirm tool covers RN and LPN/VN licenses from participating boards. For nurse aides, check the state registry. Nursing homes must get registry verification before using someone as a nurse aide (42 CFR 483.35(d)).

We cover this in detail in our separate guide on nurse license verification.

Exclusion checks

Check the HHS-OIG List of Excluded Individuals/Entities (LEIE) before placement. Facilities that bill Medicare or Medicaid can face civil money penalties for using an excluded person. OIG says no statute or regulation requires providers to check the LEIE, but that checking monthly best minimizes liability. OIG also recommends that facilities screen agency nurses or confirm the agency does it, for example by keeping the agency's screening records. Many contracts also ask for SAM.gov and state Medicaid list checks.

We cover this in detail in our separate guide on OIG exclusion screening.

Background check and FCRA consent

If you use a background check company, the FCRA applies. The FTC says that before you get the report, you must tell the applicant in writing, in a stand-alone document, that you may use it for job decisions. The notice cannot be part of the job application. You must also get the person's written permission.

Before you reject or remove someone because of the report, the FTC says you must give them a notice with a copy of the report and a copy of "A Summary of Your Rights Under the Fair Credit Reporting Act." After the decision, an adverse action notice is also required.

The scope of the search usually comes from state law and the client. Nursing homes may not employ or engage anyone found guilty by a court of resident abuse, neglect, exploitation, misappropriation of property, or mistreatment, or anyone with a related nurse aide registry finding (42 CFR 483.12(a)(3)).

Drug screen, TB, immunizations, and respirator fit

Joint Commission's staffing certification file checklist lists a drug screen "according to organization or customer requirements." For most healthcare jobs, the panel and timing come from your policy, the client, or state law.

Health records are where federal rules and CDC guidance come in. CDC's 2019 recommendations say all U.S. health care personnel should have baseline TB screening. OSHA's Bloodborne Pathogens standard says the employer must make the hepatitis B vaccine available to employees with occupational exposure. OSHA's Respiratory Protection standard requires a medical evaluation before a fit test, and a fit test before first use of a tight-fitting respirator such as an N95, and at least once a year after that.

We have separate guides on healthcare worker vaccines, TB screening, N95 fit testing, and hepatitis B declinations.

BLS/ACLS/PALS, skills checklists, and competency

Life support cards such as BLS, ACLS, and PALS are usually set by the facility and the unit. Joint Commission's staffing file checklist lists CPR "according to organization requirements." Keep a copy of each current card and its expiration date.

A skills checklist, as the term is usually used in staffing, is a worker's own rating of their experience with tasks in a specialty. It is a self-report. A competency assessment is different. It is an evaluation of whether the person can actually do the work, such as a test or a skills check by a qualified clinician.

Joint Commission's staffing certification checklist calls for initial and ongoing evaluation of competency. For hospitals, Joint Commission's requirements say staff competence is first assessed and documented during orientation, then once every three years or more often if policy or law requires. For nursing homes, federal rules say nurse aides must be able to demonstrate competency in the skills needed for residents' care (42 CFR 483.35(c)).

Orientation, facility items, and Form I-9

Joint Commission's staffing certification checklist includes documentation that the worker received orientation from the staffing firm. The facility will also orient the worker to its own policies. Joint Commission says the facility's contract should state that the firm will provide only staff qualified by education, training, licensure, and competence as the facility defines them. Read each contract for facility-specific items, such as unit tests, policy sign-offs, or badge forms.

Form I-9 is a federal requirement for your agency as the employer. USCIS says every U.S. employer must complete Form I-9 for each person hired. The employee completes Section 1 no later than the first day of employment. The employer completes Section 2 within 3 business days of the first day of work for pay. USCIS says staffing agencies may use either the date the employee is assigned to their first job or the date they enter the assignment pool as the first day of employment.

Keep each Form I-9 for 3 years after the date of hire or 1 year after employment ends, whichever is later. Do not send it to USCIS.

Common questions

Which items are federal requirements for the staffing agency itself?

Form I-9 for every hire, FCRA disclosure and consent when you use a background check company, and OSHA duties for workers with blood exposure or respirator use. Many other items are federal duties of the facility that it passes to you by contract.

Is a skills checklist the same as a competency assessment?

No. A skills checklist is usually the worker's self-rating of experience. A competency assessment evaluates whether the person can do the work. Joint Commission's staffing certification checklist calls for initial and ongoing evaluation of competency.

Is a drug screen required by federal law for nurses?

We did not find a general federal rule requiring one for healthcare staffing. Joint Commission's staffing certification checklist lists a drug screen according to organization or customer requirements. Check state law and your contracts.

When is Form I-9 due for a per diem nurse?

Section 1 is due by the first day of employment and Section 2 within 3 business days of the first day of work for pay. USCIS says staffing agencies may treat either the first assignment date or the date the person enters the assignment pool as the first day of employment.

Do a hospital's Joint Commission standards apply to our workers?

Yes, when they provide patient care. Joint Commission's FAQ says its Human Resources and National Performance Goals chapters apply to contracted staff, and that organizations must manage contracted staff just as they manage employees. That is why hospitals ask you for license, competency, and other proof.

How often should these items be updated?

It depends on the item. Licenses at renewal, exclusion checks monthly as OIG suggests, fit tests at least yearly, competency per the facility's policy, and anything else on the client's schedule. Track every expiration date.

Sources

Related guides

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