Head Start Requirements on Background Checks and New Hires

By Published On: May 23, 2017

At our trainings on the Head Start Program Performance Standards, we always get a lot of questions on the requirements for background checks on new hires.  What do you need to know?

Who is subject to background checks?  A Head Start agency must perform a background check on all new employees, and on contractors and consultants who:

  • have contact with children and families; or
  • provide direct services to children and families; or
  • could have unsupervised access to children and families.

What background checks must be performed?  The simplest way to think about the new background check requirements is to break them down into three timeframes:  before hire, after conditional hire, and every five years.

  • Before hire. In addition to conducting an interview and verifying references, before hiring or entering into a contract, Head Start agencies must:
    • conduct a sex offender registry check; and
    • obtain either:
      • State or tribal criminal history records, including fingerprint checks; or,
      • Federal Bureau of Investigation criminal history records, including fingerprint checks.
  • After hire. Within 90 days of hiring or entering into a contract, Head Start agencies must:
    • obtain State or tribal criminal history records, including fingerprint checks, or Federal Bureau of Investigation criminal history records, including fingerprint checks, whichever was not obtained before hire; and,
    • obtain child abuse and neglect state registry checks.
    • Important! Employees and contractors must not have unsupervised access to children until these background checks have been completed.
  • Every 5 years. For current employees and contractors who meet the requirements listed above, a Head Start agency must, every 5 years:
    • conduct a sex offender registry check;
    • obtain State or tribal criminal history records, including fingerprint checks;
    • obtain Federal Bureau of Investigation criminal history records, including fingerprint checks; and
    • obtain child abuse and neglect state registry checks.

When are the new background check requirements effective?  The Office of Head Start delayed the effective date of the new background check requirements.  Head Start agencies must implement the new requirements by September 30, 2017.

Want to know more? Read some of our other blog posts about human resources and governance.  Interested in training?  Check out our in-person training focused on Head Start Human Resources Requirements or our webinar on Environmental Health and Safety this week and Managing Human Resources in Head Start in Compliance with the New HSPPS. Follow us on Twitter and Facebook for even more updates!


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