How should a background check company document an unable to verify employment verification?

Close an unable-to-verify employment verification as a status with a reason, not a finding. Put the signed authorization, independently sourced contact, the attempt log, and recordings of live calls on the order so the TAT clock can stop.

This is the close for a verifications manager at a mid-size background-check firm on TazWorks or AIO Data that already buys The Work Number and still has restaurants, trucking shops, and small LLCs in the leftover queue.

Unable to verify is a status, not a finding

The report line is that the source did not confirm the claim in the time available. It does not mean the applicant lied. It is not a discrepancy. Screening operators on Reddit, including a former background-screener in r/recruitinghell, treat unable to verify as a common close and put the hiring decision on the client. Write it that way.

The Work Number still wins the files it holds, in seconds. Superunit’s State of Employment Verification 2026, from 200,000-plus verifications in its own leftover mix, says about 65 percent of files still needed calls, emails, or faxes. Those leftover files are the ones that land as unable to verify when outreach runs out. What to do when The Work Number has no record is the miss. How to verify employment for employers that are not in The Work Number is the chase. This page is the packet once the chase is done.

A consumer reporting agency preparing that packet follows 15 U.S.C. § 1681e(b): reasonable procedures to assure maximum possible accuracy. The FTC’s screening-company guidance, read 2026-10-09, restates that duty. A three-call voicemail string with no independently sourced number is a thinner procedure than a time-stamped log through the client’s SOP. Rules vary. Check counsel. This is not legal advice.

Do not mix this close with a dispute. Under 15 U.S.C. § 1681i(a)(5), if a consumer disputes an item and a reinvestigation cannot verify it, the agency deletes or modifies that item. An original leftover that never got an employer on the line is a documented non-response on the order, not a deletion.

What the closed file has to contain

The file can leave the queue in three states. Verified is employer-confirmed facts in the employer’s wording. Partial is some fields confirmed and the rest still open. Unable to verify is the SOP count met, no confirmation, and the reason written in plain words.

Item	Put it on the order	Leave it off the report	Why
Signed authorization and permissible purpose	Yes, before the first dial	Outreach with no auth on the file	15 U.S.C. § 1681b
Independently sourced HR or payroll number, plus where it came from	Yes	The applicant’s number as the only contact	Clarifacts flags applicant-supplied numbers as a set-up risk, read 2026-10-09
Employer-of-record name	The W-2 / PEO / DBA name	The store name alone	Superunit’s calling-HR guide, read 2026-10-09, flags acquisitions, DBAs, and staffing firms
Attempt log	Every touch	A single “called, no answer” note	PBSA BSAAP clause 5.7
Recording and transcript of live calls	Yes, with recording consent stated	A voicemail treated as a result	Failed attempts still belong on the log
Reason for the close	Silent line, refused, wrong entity, closed shop, no HR	“Failed” or “discrepancy”	Status, not a finding
Applicant W-2, paystub, or offer letter	Only if the SOP accepts docs as partial	Posted as employer-confirmed VOE	PBSA June 2024 opinion letter
Opinion about the applicant	Never	Guessing they lied	Report what the source did and did not confirm

Each order needs the applicant’s signed authorization and a permissible purpose before outreach starts. Business lines are the default. Recording and autodial or AI-voice rules vary by state and by the FCC’s TCPA reading. Check counsel.

Log every attempt the way an auditor will read it

PBSA’s Background Screening Agency Accreditation Program standard, clause 5.7, requires accredited CRAs to document every verification attempt and its result. A June 2024 PBSA opinion letter, read 2026-10-09, repeats the audit minimum: date and time; method of contact, such as the number dialed, fax, email, or mailing address; name and title of the contact; and the result. The April 2018 BSAAP audit criteria also want the CRA worker who made the attempt.

Superunit’s April 15, 2026 calling-HR guide, read 2026-10-09, adds request date, verifier, employer, contact source, number used, each attempt’s time, outcome, facts confirmed, escalation, and final disposition. A log that only records completed verifies leaves a hole the next specialist cannot reconstruct.

Write the outcome in the same vocabulary every time: reached HR, left voicemail, no answer, wrong number, refused to verify, sent to a third-party vendor, or employer of record is a PEO. Clause 5.4 of the same standard tells accredited firms to disclose to clients, before the work, how many attempts they make and what counts as an attempt. Put that number on the order so the close matches what the client already bought.

The attempt count is the client’s SOP

There is no federal number of calls. Superunit’s 2026 report puts a completed leftover at a median of 5 touches, with 17 percent of completed files at 11 or more, on 79,045 completed verifications. Its calling-HR guide calls fewer than three attempts with no escalation hard to defend in an audit. That is Superunit’s pattern, not a statute. Follow the client’s SOP.

Employers are not required to answer a private verifier. Experian Employer Services, dated October 3, 2023, read 2026-10-09, says a request from an employer, landlord, or mortgage lender is not one the law forces a private employer to return; government-agency requests are the usual exception. Superunit’s calling-HR guide, citing SHRM-sourced guidance, says a refusal or a silent line is a valid outcome when the attempts are logged.

A voicemail is not a close. Sequential outreach spends the TAT on the wait. Phone, email, and fax on the same day puts more of the SOP count on the log before the clock runs out. Superunit’s mix puts email at about 52 percent of leftover outreach and phone at about 46 percent.

Pay-on-success leftover vendors do not bill a silent employer, so that file stays on the CRA’s TAT. Superunit starts at $1.50 per completed order and does not charge when it cannot confirm, superunit.com/pricing, read 2026-10-09. A documented non-response is how some CRAs stop the clock once the SOP is met.

Do not treat a W-2 as a verified employment

When the source will not talk, many floors ask the applicant for a W-2, a paystub, or an offer letter. Keep those papers on the order. Do not relabel them as employer-confirmed VOE. The same June 2024 PBSA letter says a verification built on applicant documents leaves unverified any data that method cannot show, and names job title as the usual gap. Mark the packet partial. Leave title, rehire, and reason-for-leaving blank unless a source confirmed them.

The same gap shows up when the store on the application is not the employer of record. Call the diner and a manager who cannot disclose is not a close. Log the PEO, the staffing firm, or the franchisee, and keep going. A “no record of this person” from the right entity is a different reason than a silent line at the wrong number. Write the reason you actually have.

Mortgage leftover on the same close

Fannie Mae Selling Guide B3-3.1-04, dated 10/07/2026, read 2026-10-09, still requires a verbal verification of employment for each borrower using employment income, no more than 10 business days on or before the note date. Announcement SEL-2026-09, also 10/07/2026, removed the prescribed methods. Lenders may use a method that is reasonable, verifiable, and appropriate. The timing did not move. If the required verification cannot be obtained before loan delivery, the loan is ineligible for sale to Fannie Mae.

A leftover VVOE that will not confirm is the same packet on a shorter clock: independently sourced contact, a documented conversation, or a documented no the closer can see the same day.

Pull last month’s unable-to-verify files from TazWorks or AIO Data and open the attempt logs. If a file closed on a voicemail, a single applicant-supplied number, or a note that says only “no answer,” that is the packet to recut before the next client audit.