Home Care Staffing Requirements: Background Checks, TB Tests and More

A family calls your home care agency on Friday afternoon. Their mother is coming home from the hospital on Monday and needs a caregiver for mornings and evenings. You have a great candidate lined up, but her TB test result is still "in the mail", her fingerprint appointment is next week, and the CPR card she sent is a blurry photo of a card that may have expired in the spring. The family is waiting, your scheduler is anxious, and nobody on the team has time to chase.

That is everyday life for home care staffing. Home care staffing requirements are set largely at the state level, they differ depending on whether you place companion caregivers, personal care aides or certified home health aides, and they come with expiry dates that never line up neatly. Missing one item can mean a caregiver cannot start, or worse, an issue surfaces during a state survey or a client complaint.

This is part 3 of our US Staffing Compliance Checklists series. Below you will find a state-aware approach to caregiver onboarding documents: background checks and fingerprinting, TB screening, training and certification, Form I-9, and how to keep track of everything that expires. It is general guidance, so always confirm the details with your state health department, licensing agency or legal counsel.

Why home care staffing requirements vary by state

There is no single national rulebook for home care workers. Federal rules play a role, especially for home health aides working for Medicare-certified home health agencies, where federal regulations set training and competency standards. But most of the day-to-day requirements, such as which background checks are required, whether fingerprinting is needed, how often TB screening happens and which training hours count, come from state law and state licensing rules.

Different roles, different rules

It helps to group your workforce before building a checklist:

• Companion or homemaker caregivers: non-medical support such as meal prep, light housekeeping and companionship. Requirements are often lighter but vary widely by state.
• Personal care aides (PCAs): hands-on help with bathing, dressing and mobility. Many states require specific training hours and background checks.
• Home health aides (HHAs) and certified nursing assistants (CNAs): often subject to federal training standards plus state certification or registry listing.
• Nurses (LPNs and RNs): require an active state nursing license, verified with the state board.

If your agency operates in more than one state, build a separate checklist per state and per role. One master list with footnotes quickly becomes a list nobody reads.

Where to find the rules

Start with your state's department of health or the agency that licenses home care organizations. Medicaid waiver programs and managed care organizations may add their own requirements, and some clients will too. Keep a short note of the source for each requirement so you can revisit it when rules change.

Caregiver background check and fingerprinting

The caregiver background check is usually the item that takes longest and causes most of the start-date delays.

What is commonly required

Depending on the state and role, a background check may include:

• State criminal history checks, often through a state-run program for direct care workers.
• Fingerprint-based checks, sometimes including an FBI search, required for many caregiver roles in some states.
• Abuse and neglect registry checks, and checks of the state nurse aide registry where relevant.
• Federal exclusion list screening, such as the OIG List of Excluded Individuals and Entities, particularly where Medicare or Medicaid funding is involved.
• Sex offender registry searches.

FCRA basics

If you use a third-party consumer reporting agency for background checks, the Fair Credit Reporting Act (FCRA) applies. That generally means a clear, standalone disclosure, written authorization from the candidate, and a pre-adverse and adverse action process if you decide not to place someone based on the report. State and local fair chance laws may add further steps. Get your forms reviewed and keep signed authorizations on file.

Keep the evidence

Collect and store the authorization, the results or clearance letter, and the date the check was completed. Fingerprint clearances in some states are tied to the employer, so check whether a caregiver's existing clearance transfers to your agency.

TB tests and health screening

Tuberculosis screening is one of the most common requirements for caregivers, though the exact rules differ by state and setting.

What to collect

Many states and employers ask for one of the following before a caregiver starts:

• A TB skin test (often a two-step test for new hires), with the date read and the result.
• A TB blood test (IGRA), with the lab report.
• For those with a positive result, a chest X-ray report and a symptom screening form, following your state's guidance.

Some states require annual screening or an annual symptom questionnaire; others rely on a risk assessment. CDC guidance for health care personnel is a useful reference, but your state's rules decide what you must actually hold.

Other health items that may come up include a physical exam or health statement, immunization records, and flu vaccination records where clients or programs ask for them.

The blurry-photo problem

TB results are where low-quality uploads cause real trouble. A skin test record needs the date placed, the date read, the measurement and the signature of the person who read it. A cropped photo that cuts off the reading date is not evidence. Ask for the full document every time.

Training, certifications and the home health aide requirements

Certifications to collect

Home health aide requirements in brief

For HHAs working for Medicare-certified home health agencies, federal rules set minimum training and competency evaluation standards, plus ongoing in-service training each year. Many states add their own hours or topics. If you staff HHAs into certified agencies, ask the client what they need to see and keep it on the caregiver's record.

Don't forget Form I-9

Every caregiver you employ must complete Form I-9. Section 1 must be completed by the caregiver no later than their first day of work, and you must complete Section 2 within three business days of their start date. If you use E-Verify, follow its rules on timing and photo matching. Check USCIS guidance for the current list of acceptable documents.

Tracking expiries before they become emergencies

Home care compliance is never "done". CPR cards expire, TB screening comes around again, licenses renew, driver's licenses and auto insurance lapse. The agencies that stay ahead treat expiries as a schedule, not a surprise.

A simple approach:

1. Record the expiry date the moment a document is accepted, not later.
2. Start chasing well before expiry: for most items, around 30 days ahead gives the caregiver time to book a class or a test.
3. Ask only for what is missing. A caregiver who receives one clear request for one document is far more likely to respond than one who gets a long generic list.
4. Escalate to a person if the deadline gets close, so a scheduler can plan cover.

This is where automation pays off. Amy, the GettingDocs AI assistant, chases caregivers on WhatsApp and on email from your agency's own domain, in your agency's voice. Amy checks each upload is readable and the right document, rejects blurred photos and cut-off pages and asks again, and files accepted documents onto the caregiver's record in your ATS (Recruit CRM, Crelate, Zoho Recruit and JobAdder today). See how it works for home care staffing agencies.

Key takeaways

• Home care staffing requirements are mostly state-driven, so build a checklist per state and per role.
• Background checks and fingerprinting usually take longest; start them first and follow FCRA steps when you use a screening vendor.
• TB screening documents must be complete, with dates and results visible, not cropped photos.
• Certifications, training hours and Form I-9 belong in every caregiver file.
• Track every expiry and chase renewals early so caregivers stay on schedule.

Use the checklist tables above as your starting point and adapt them to your state. When you are ready to stop chasing caregivers by hand, book a call with GettingDocs and we will walk through your caregiver checklist with you.

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Please note: this article is general information, not legal advice, and was correct at the time of writing (October 2026). Rules and guidance change, so please check the latest guidance from the Federal Trade Commission, the CDC and USCIS I-9 Central before relying on it.