LuluCare Background Check & Credential Verification Policy

Version 1.1 · 2026-07-19

Last Updated: July 19, 2026

1. Purpose and Scope

This Background Check and Credential Verification Policy (the "Policy") explains how Lulu Staffing LLC, doing business as LuluCare ("LuluCare," "we," "our," or "us"), verifies the identity, qualifications, eligibility, and ongoing fitness of Healthcare Professionals who seek to participate in the LuluCare marketplace.

This Policy is incorporated into the LuluCare Marketplace Terms of Service, Healthcare Professional Agreement, Privacy Policy, and Community Standards & Acceptable Use Policy. It applies to applicants, active Healthcare Professionals, and any other individual whose eligibility LuluCare is authorized or required to verify.

LuluCare may use third-party providers, licensing boards, government databases, public records, Facilities, educational institutions, prior employers, references, and other lawful sources to conduct verification. Verification does not guarantee competence, future eligibility, suitability for every Assignment, or the accuracy of information supplied by third parties.

Some processes described in this Policy are forward-looking. Where a capability is planned but not yet operational, this Policy describes LuluCare's intended process. Third-party background screening through a consumer reporting agency is operational and is initiated at the conclusion of onboarding, as described in Section 6.

2. Eligibility Is Conditional and Ongoing

Creating an Account or submitting documents does not guarantee approval. Marketplace participation is conditional upon successful completion of LuluCare's applicable onboarding requirements and remains subject to continuing review.

LuluCare may approve, condition, restrict, suspend, deactivate, or terminate eligibility based on information reasonably relevant to patient safety, legal compliance, professional qualifications, identity, fraud prevention, marketplace integrity, or Facility requirements.

3. Information and Documents That May Be Required

Healthcare Professionals may be required to provide or authorize verification of:

• legal name, date of birth, contact information, and identity information;

• a verified United States mobile number;

• an emergency contact;

• government-issued identification and identity-verification photographs;

• Social Security number or other information submitted directly to an authorized screening or payment provider when legally required;

• professional licenses, registrations, certifications, permits, and license numbers;

• education, training, continuing education, work history, skills, and references;

• Basic Life Support, CPR, specialty, or role-specific certifications;

• tuberculosis screening, chest X-ray documentation, vaccination records, physical-clearance documentation, or other occupational-health records required by law or a Facility;

• professional liability insurance or other required insurance;

• criminal-history information obtained through an authorized consumer reporting agency (see Section 6);

• sanctions, exclusions, disciplinary actions, license restrictions, and government-program eligibility;

• information needed to confirm authorization to work or perform services where applicable;

• Facility-specific onboarding documents and acknowledgments;

• acceptance of the applicable LuluCare agreements, including the Terms of Service, Privacy Policy, E-Sign Consent, and Healthcare Professional Agreement.

The specific credentials LuluCare collects today for nurse eligibility are: (1) government-ID identity verification; (2) a professional license; (3) CPR/BLS certification; (4) tuberculosis test or chest X-ray documentation; and (5) background-check authorization (consent), together with an emergency contact. LuluCare is in the process of adding a verified United States mobile number and acceptance of the Terms of Service, Privacy Policy, E-Sign Consent, and Healthcare Professional Agreement. A consolidated "Health Clearance" (occupational-health clearance) is planned to replace the current tuberculosis/physical requirement and is not yet in effect.

Users must provide complete, authentic, accurate, legible, and current information. Documents may not be forged, altered, borrowed, expired, misleading, or submitted on behalf of another person.

4. Identity Verification

LuluCare may verify identity through government identification, photographs, database checks, device or account information, payment-provider verification, knowledge-based questions, live verification, or other reasonable methods.

LuluCare may require additional verification when information is inconsistent, incomplete, expired, difficult to authenticate, associated with suspected account sharing, or otherwise presents a security or fraud concern.

A Healthcare Professional may not allow another person to complete identity verification, onboarding, screening, Clock Events, or Assignments on their behalf.

5. Professional License and Credential Verification

LuluCare may verify Credentials directly with issuing authorities, online licensing databases, credentialing vendors, educational institutions, certification organizations, employers, references, or other lawful sources.

Verification may include:

• license type, number, state, status, issue date, and expiration date;

• restrictions, conditions, probation, suspension, revocation, or disciplinary history;

• certification validity and renewal status;

• education or training completion;

• scope-of-practice eligibility;

• Facility-specific qualification requirements;

• professional liability insurance status where required.

A document upload alone does not establish verification. LuluCare reviews submitted documents through an administrative workflow with statuses of Pending, Verified, and Rejected, and may require primary-source verification or additional documentation before activating eligibility.

6. Background Checks and Consumer Reports

Background screening is the final step of Healthcare Professional onboarding. As the last onboarding step, LuluCare presents a separate, standalone Fair Credit Reporting Act (FCRA) disclosure and obtains the Professional's written authorization. Upon that authorization, LuluCare initiates background screening through a third-party consumer reporting agency (Checkr), and marketplace eligibility depends on the results.

Where authorized and legally permitted, LuluCare obtains criminal background checks, identity reports, employment or education verification, motor-vehicle records when relevant, professional-history reports, or other consumer or investigative consumer reports from the consumer reporting agency.

Before obtaining any such report where required by law, LuluCare provides a separate, standalone disclosure and obtains written authorization. The screening provider may require the individual to review and accept its own notices, terms, and privacy policy.

This Policy is not itself the legally required standalone background-check disclosure or authorization, and it is not part of the Terms of Service. The standalone Fair Credit Reporting Act (FCRA) disclosure and authorization — a document that consists solely of the disclosure and the authorization — will be presented separately when applicable.

7. Sanctions, Exclusions, and Regulatory Screening

LuluCare may screen Healthcare Professionals against sources that may include:

• federal and state healthcare-program exclusion lists;

• professional licensing-board records;

• sanctions and disciplinary databases;

• abuse, neglect, or misconduct registries where legally available and relevant;

• sex-offender registries where legally permitted and relevant;

• government watchlists or debarment lists where applicable;

• Facility-required screening sources.

A confirmed exclusion, sanction, disqualifying license status, or other legal prohibition may result in immediate ineligibility or suspension.

8. Individualized Review and Relevance

When a consumer report is obtained, LuluCare does not apply criminal-history information through an automatic blanket rule where individualized consideration is required by law.

When legally applicable, LuluCare may consider factors such as:

• the nature and gravity of the conduct;

• the time that has passed;

• the relationship between the conduct and the role or Assignment;

• evidence of rehabilitation or mitigation;

• accuracy or completeness of the report;

• patient, resident, Facility, coworker, financial, or data-security risk;

• licensing, regulatory, insurance, or Facility requirements;

• whether a legal exception or mandatory disqualification applies.

Nothing in this Section requires LuluCare to disregard a legal prohibition, licensing restriction, exclusion, Facility mandate, patient-safety concern, or material fraud risk.

9. Preliminary Adverse Decisions

When LuluCare may take adverse action based in whole or in part on a consumer report and a pre-adverse-action process is required, LuluCare will provide the legally required notice and materials, which may include:

• a copy of the report;

• a summary of applicable consumer rights;

• identification and contact information for the screening provider;

• notice of the contemplated decision;

• a reasonable opportunity to dispute inaccuracies or provide relevant information.

No final adverse decision will be based on a consumer report until the applicable response period and legally required process have been completed.

10. Disputes and Corrections

Individuals who believe a consumer report is inaccurate or incomplete should dispute the information directly with the screening provider using the contact information included with the report or notice.

Individuals may also notify LuluCare at support@trylulucare.com. LuluCare may pause a final eligibility decision while a timely, good-faith dispute is pending when required by law or reasonably appropriate.

Credential discrepancies should be supported with official records, corrected documents, issuing-authority confirmation, or other reliable evidence. LuluCare is not required to accept unsupported statements in place of verifiable documentation.

11. Final Adverse Decisions

If LuluCare makes a final adverse decision based in whole or in part on a consumer report, LuluCare will provide any final notice required by law. The notice may identify:

• the decision taken;

• the screening provider's name and contact information;

• that the screening provider did not make the decision;

• the individual's right to dispute the report;

• any additional rights required under applicable law.

Adverse decisions may include denial of marketplace eligibility, conditional approval, limitation of available roles, suspension, deactivation, removal from an Assignment, or termination of Account access.

12. Credential Expiration and Renewal

Healthcare Professionals are responsible for monitoring and renewing their Credentials before expiration. LuluCare may provide reminders as a courtesy but does not guarantee that reminders will be sent or received.

A Healthcare Professional may become ineligible to apply for, accept, or perform Assignments when a required Credential is expired, suspended, restricted, unverifiable, or incomplete.

Renewal documents must be submitted within the time and format required by LuluCare. LuluCare may require reverification before restoring eligibility.

13. Ongoing Monitoring and Reverification

LuluCare may conduct periodic or event-based reverification throughout marketplace participation. Monitoring may include license status, sanctions, exclusions, criminal-history updates where legally authorized, insurance, expiring Credentials, identity, account activity, Facility reports, or other eligibility information.

Reverification may occur:

• at scheduled intervals;

• before or after an Assignment;

• when a Credential approaches expiration;

• after a complaint, incident, discrepancy, or safety concern;

• when required by a Facility, insurer, regulator, or law;

• when account activity suggests fraud or identity misuse;

• when LuluCare changes its eligibility requirements.

Continued participation constitutes agreement to provide updated information and complete reasonable reverification requirements, subject to any separate authorization required by law.

14. Duty to Report Changes

Healthcare Professionals must promptly notify LuluCare of material changes, including:

• expiration, suspension, restriction, surrender, or revocation of a license or certification;

• disciplinary action or investigation by a licensing or regulatory authority where disclosure is legally required;

• exclusion, debarment, sanction, or loss of government-program eligibility;

• criminal charges or convictions where disclosure is legally required;

• loss of required insurance;

• changes in identity or authorization information;

• any condition that makes the individual unable to safely or lawfully perform an Assignment;

• any inaccurate document or information previously submitted.

Failure to disclose a material eligibility change may independently result in suspension or termination.

15. Facility-Specific Requirements

Facilities may impose lawful Assignment-specific requirements in addition to LuluCare's general marketplace requirements. A Healthcare Professional who is generally eligible for LuluCare may still be ineligible for a particular Facility or Assignment.

LuluCare may share verified credential status, qualification information, screening status, and (in a future release) Credential expiration dates with Facilities as described in the Privacy Policy. Facilities see verification status only; they do not have access to the underlying documents. Government-issued identification and health documents are visible to LuluCare administrators only and are not disclosed to Facilities. LuluCare will not disclose a complete background report to a Facility unless authorized and legally permitted.

Facilities remain responsible for determining whether a Healthcare Professional satisfies their own legal, regulatory, accreditation, contractual, clinical, and operational requirements.

16. Confidentiality and Data Handling

Credential and screening information will be handled in accordance with the LuluCare Privacy Policy and applicable law. Access may be limited to personnel, service providers, Facilities, advisors, regulators, or others with a legitimate and lawful need. Government-issued identification and health documents are accessible only to LuluCare administrators.

Users must not submit patient records or patient-identifying clinical information during credentialing or screening.

17. Fraud and Misrepresentation

LuluCare may immediately suspend or terminate eligibility when it reasonably suspects:

• forged, altered, borrowed, or fraudulent documents;

• identity theft or account sharing;

• false work, education, license, health, or certification information;

• attempts to manipulate a screening provider or issuing authority;

• concealment of a material eligibility fact;

• use of another person's screening or health records;

• interference with reverification or investigation.

LuluCare may preserve relevant records, notify affected Facilities, reverse marketplace decisions, and report suspected misconduct to licensing boards, screening providers, insurers, regulators, or law enforcement when permitted or required.

18. Administrative Review and Enforcement

LuluCare may request additional documents, place an Account under review, temporarily restrict Assignments, or suspend eligibility while a verification issue is investigated. Temporary review does not constitute a final determination of wrongdoing.

Marketplace eligibility decisions are administrative decisions concerning use of the Platform. They are not licensing, employment, judicial, or regulatory determinations.

19. Reconsideration Requests

A Healthcare Professional may request reconsideration of a credential-based or eligibility decision by emailing support@trylulucare.com with relevant official documentation.

A reconsideration request does not automatically restore eligibility or pause a safety-related restriction. LuluCare may decline repetitive, abusive, untimely, or unsupported requests, subject to any non-waivable legal rights.

20. Changes to This Policy

LuluCare may update this Policy to reflect changes in law, marketplace operations, screening providers, Facility requirements, or patient-safety standards. Material updates may be communicated through the Platform, email, or another reasonable method.

21. Contact Information

Questions about this Policy may be directed to:

Lulu Staffing LLC d/b/a LuluCare

Email: support@trylulucare.com

Questions or disputes about a third-party consumer report should also be directed to the screening provider identified in the applicable disclosure or notice.

ACKNOWLEDGMENT

BY SUBMITTING CREDENTIALS, AUTHORIZING SCREENING, OR PARTICIPATING IN THE LULUCARE MARKETPLACE, EACH HEALTHCARE PROFESSIONAL ACKNOWLEDGES THAT THEY HAVE READ AND UNDERSTOOD THIS POLICY AND AGREE TO PROVIDE ACCURATE, AUTHENTIC, AND CURRENT INFORMATION.