Privacy Act of 1974; Matching Program
CMS is launching a new data matching program under the Privacy Act, which may affect employers using AI hiring tools that rely on CMS data (e.g., Medicare/Medicaid) for background checks or verification. The program imposes new notice and consent requirements for data matching.
Aforeworn detected this change in the AI in Hiring & Employment Screening space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Enterprise employers, staffing/RPO firms, HR-tech/ATS vendors, and background-screening providers that use CMS data in automated employment decisions or background checks. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Effective upon publication; compliance expected within 30 days.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors AI in Hiring & Employment Screening continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
A new matching program between CMS and other agencies requires additional Privacy Act compliance, including notice to individuals and data use agreements.
Who it affects
Enterprise employers, staffing/RPO firms, HR-tech/ATS vendors, and background-screening providers that use CMS data in automated employment decisions or background checks.
What you must do
Review any data matching activities involving CMS data to ensure compliance with the new program requirements, including updating privacy notices and obtaining necessary consents.
Deadline
Effective upon publication; compliance expected within 30 days.
Source: https://www.federalregister.gov/documents/2026/07/06/2026-13572/privacy-act-of-1974-matching-program
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