Pre-Screening Services: One of the Most Important Business Components Today

History has proven time and again that the risks of hiring based on a “gut feeling” can be significant. Nevertheless, countless organizations still hire candidates without screening them adequately or at all. They skip pre-employment screening, background checks, or lack the necessary auditing protocols. In doing so, employers presume the people they hire will put their best foot forward. Below are some statistics to give you an idea of how important it is to establish a reliable employment screening program.

• An estimated 40% of people lie on their resumes while 75% of employers have found a lie on an employee’s resume [Indeed]
• Roughly eight nonfatal violent workplace offenses were reported per 1,000 U.S. workers between 2007 and 2015 [cdc.gov]
• Healthcare workers account for 75% of workplace assaults [ABC News]
• Employee crime costs U.S. businesses approximately $50 billion annually [CNBC]
• Around 22% of human resources staff reported lacking skills to interview and hire people effectively [CareBuilder]
• Negligent hiring lawsuits net an average of $1 million with courts often awarding judgments exceeding several million dollars [Forbes]

Employers must remember that they are responsible for an employee’s behavior—in some cases, this even includes behavior occurring away from the workplace and off the clock. It can also include physical, psychological, or financial harm to people or the destruction or loss of property.

Disturbing trends related to workplace violence, employee theft, negligent hiring lawsuits, as well as the rising costs in recruitment and training has spurred a growing number of organizations to establish reliable employment screening programs. Employment screening and background checks serve a crucial role in exercising reasonable care during the hiring process, reducing the employer’s liability if an employee violates someone’s rights, commits a crime, among other things.

Thoroughly, properly formulated, and professionally administered pre-screening services reduce employer risk. They also improve overall business outcomes. Additional benefits include:

• Assessing an applicant’s past behavior and character, allowing you to greatly reduce employee theft and shrinkage
• Certain industries or jobs require employee screening to meet local, state, and federal regulations. Certain organizations may also stipulate employee screening in their contracts
• Employment screening helps employers make better hiring decisions, resulting in a more secure work environment for employees and customers
• Employment screening results in a higher quality candidate pool by deterring undesirable candidates
• Employment screening exhibits an employer’s due diligence in the hiring method
• Employment screening ensures candidates have the required credentials for the position and ensures higher workforce standards
• Employee Screening allows for greater protection to brand equity and reputability
• Employee Screening prevents management from hiring someone based on their own judgment

Organizations have particular interests and aspirations that can be furthered by a professionally-designed employment screening program. Millennial’s pre-employment screening services are customizable to your organization’s needs. Our highly trained agents address the risk tolerance and goals of your organization.

Approximately 60 million Americans currently receive Social Security benefits every month. While a large percentage of those benefits help older adults who are retired, a significant number of recipients ranging in age also get Social Security Disability Insurance (SSDI). For those suffering from a severe disability or clearly meet the Social Security Administration’s (SSA) requirements for being disabled, they may get approved easier than others.

While the SSA automatically approves a few disabilities for benefits, they’re not the only disabilities that qualify for insurance. In order for an attorney to get a better picture of this, they would have to use what is known as the “Blue Book.” The Blue Book is the SSA’s medical guide used to evaluate every SSDI application, particularly for people with severely disabling impairments. The Blue Book is composed of two parts: Part A for adults and Part B for children that qualify to receive SSDI. It covers a variety of severe impairments ranging from Trisomy 21 Down Syndrome to Cerebral Palsy to terminal cancer.

It states in the SSDI Qualifying Conditions section of the SSA’s FAQ:

“In addition to listing qualifying conditions for SSDI, the Blue Book also outlines the medical evidence required for approval with disability. Essential pieces of medical evidence are detailed under the individual listing for each condition.

“There is also information provided at the beginning of each major section of the Blue Book, describing how the SSA evaluates disabilities that fall under that body system. This introductory information commonly includes the tests and other crucial details the SSA must see in your medical records in order to grant approval for disability benefits.

“For this reason, it’s important for you, your doctor, and/or your disability advocate or attorney to not only look at the qualifying conditions for SSDI but also the introduction of the Blue Book section where your condition is listed. This will give you insight into how the SSA reviews claims like yours and it will often tell you the exact tests and other medical proof need for you to be approved for benefits.”

As you can see, being able to pre-screen individuals who might qualify for SSDI  is a very powerful tool. Millennial Services quickly and efficiently screen potential disability candidates and informs attorneys if they meet the Blue Book standards set by the SSA. By allowing Millennial Services to streamline the process for you, valuable time and resources are saved.

On June 1, 2020, the Department of Justice (DOJ) issued an amended version of its guidance concerning the Evaluation of Corporate Compliance Programs, with enhanced third party management being the focus topic. In the introduction, the DOJ makes it clear what is expected from businesses in order to protect themselves.

“The ‘Principles of Federal Prosecution of Business Organizations’ in the Justice Manual describe specific factors that prosecutors should consider in conducting an investigation of a corporation, determining whether to bring charges, and negotiating a plea or other agreements. JM 9-28.300. These factors include ‘the adequacy and effectiveness of the corporation’s compliance program at the time of the offense, as well as at the time of a charging decision’ and the corporation’s remedial efforts ‘to implement an adequate and effective corporate compliance program or to improve an existing one.’ JM 9-28.300 (citing JM 9-28.800 and JM 9-28.1000).”

The guidance goes on to explain that federal prosecutors are expected to ask three questions:

1. “Is the corporation’s compliance program well designed?”
2. “Is the program being applied earnestly and in good faith?” In other words, is the program adequately resourced and empowered to function effectively?
3. “Does the corporation’s compliance program work” in practice?

Federal prosecutors begin their assessment of whether an organization’s compliance program is well designed by studying its operations from a commercial viewpoint. He or she will then evaluate how the organization identifies, assesses, and defines its risk profile. That is compared to the extent to which scrutiny and resources are appropriately assigned to the spectrums of risk. In other words, federal prosecutors investigate how and why an organization chose to establish its compliance program in a certain way; he or she will also want to know how and why its compliance program has or has not advanced over time. Below are the top five updates to the Evaluation of Corporate Compliance Programs you should be aware of.

A new sub-section has been added to the guidance that queries issues dealing with compliance and control. Some examples include:

• “Do compliance and control personnel have the appropriate experience and qualifications for their roles and responsibilities?”
• “Has there been sufficient staffing for compliance personnel to effectively audit, document, analyze, and act on the results of the compliance effort?”
• “Do compliance and control personnel have sufficient direct or indirect access to relevant sources of data to allow for timely and effective monitoring and/or testing of policies, controls, and transactions?”
• “Do the compliance and relevant control functions have direct reporting lines to anyone on the board of directors and/or audit committee?”
• “Has the company outsourced all or parts of its compliance functions to an external firm or consultant?”
•  “How has the effectiveness of the outsourced process been assessed?”

This underpins the requirement for a principal vendor control system that is employed as the central source of data veracity regarding vendors and other kinds of third-parties. Vendor data concerning monitoring activities, contracting, due diligence, risk assessments, and justification should be stored on a single system; it should allow for regular and proper reporting, conclusive testing of compliance with policies, transactions, and controls.

The DOJ continues to raise the bar with the latest update. As security issues are on the rise globally, it expects a lot more from compliance programs adopted by organizations. The Evaluation of Corporate Compliance Programs seems to be more focused on risks posed by third parties, as well as how compliance programs will identify and handle them.

The DOJ added the following question for prosecutors to use as an evaluation tool:

“Does the company engage in risk management of third parties throughout the lifespan of the relationship, or primarily during the onboarding process?”

This appraisal seems to be targeting the issue of substandard third-party risk monitoring—something that had gone unchecked in countless third-party management programs before the update. You should review your third-party vendor management program to be sure it covers the management and governance of risks. This includes contracting, onboarding, procurement, planning, due diligence, monitoring, and discontinuance.

Prosecutors are directed to apply the following guidance:

“Prosecutors should also assess whether the company knows the business rationale for needing the third party in the transaction, and the risks posed by third-party partners, including the third-party partners’ reputation and relationships, if any, with foreign officials.”

The new requirement for organizations to understand the “business rationale” that necessitates a third-party vendor. Incorporating a “business justification” in your planning and procurement process addresses the business rationale. Of course, drawing up a business justification for every type of vendor is less than practical. But it is absolutely necessary for medium to high-risk third-party business relationships.

The DOJ asserts that, once a compliance program is in place, it should be periodically revised and fine-tuned. The prosecutors will deem it a “paper program” if this is not accomplished. Updates to your compliance screening policies and techniques must be done in line with the organization’s periodic risk assessments, as well as based on previous incidents. Ideally, your compliance screening program should ultimately increase the value of the relationships you have with third-party vendors.

The DOJ updated its guidance by requiring the following:

“Prosecutors should also determine ‘whether the corporation’s employees are adequately informed about the compliance program and are convinced of the corporation’s commitment to [….] implemented, reviewed, and revised, as appropriate, in an effective manner.” JM 9-28.8

This amendment shows the DOJ’s concern about compliance officers being provided with adequate resources and sufficiently empowered to do their job. Vendor compliance screening programs have been notably under-resourced for years. Organizations need to learn quickly that insufficient resources will no longer be a justifiable excuse for non-compliance under the new DOJ guidelines. In order to guarantee adequate resources, identify all stakeholders associated with vendor management. Ensure each one of them has clearly established roles.

Millennial’s pre-screening services employ highly trained agents to make the process of pre-screening individuals and organizations a lot easier. Whether your business needs pre-employment screening, pre-screening for disability benefits, pre-qualifying potential lending and insurance applicants, third-party compliance screening, Millennial has you covered. Most importantly, you get to set the determining criteria.

Our professional remote workforce allows us to offer English-fluent, US-based prescreening support in an omnichannel contact center environment. By outsourcing this to agents and operations trained to your specification, you eliminate the possibility of error. Instead of doing disparate things and possibly missing important details, you are implementing a team of specialists focusing on one thing—identifying candidates who meet the qualifications you have set and those who are not eligible for consideration. You cannot do it all on your own, that is why high-quality pre-screening services are vital for your business.

If you have any questions about this topic or would like to know more about our pre-screening services, contact us today.