Criminal Background Checks for Matriculating Students

POLICY

In order to assure that admitted students can successfully pursue careers as health care professionals and to conform to new requirements at clinical training sites, UTHSC must assure that all entering students undergo a criminal background check (CBC) prior to matriculation. Once accepted for admission, students must complete the procedure described below.

CRIMINAL BACKGROUND CHECK PROCESS OVERVIEW

UTHSC requires that admitted students undergo a criminal background check (CBC) prior to matriculation using a process that has been established by the Tennessee Hospital Association for student background checks. The student is responsible for initiating the procedures to obtain the background check and will assume the cost of the assessment. The CB search may include the following:

  1. County Criminal Record Search - uses student address information from the prior 7 years to provide a comprehensive report on criminal records from county courthouses.
  2. A review of fraudulent activity (ID Search Plus) is obtained by matching the student's name, address and/or social security number against a credit-reporting database.
  3. A Level 3 FACIS report (Fraud and Abuse Control Information System) obtains information on a wide range of disciplinary actions affecting health care providers, ranging from exclusion and debarments to letters of reprimand and probation. A Level 3 search accesses over 800 databases in 50 states.
  4. Sex Offender Database - A database search for individuals registered as sex offenders in the selected state or jurisdiction. Information and offender level retrieved varies by location. Tennessee Abuse Registry - This registry, maintained by the Tennessee Department of Health, contains a list of persons who have abused, neglected, or misappropriated personal property of a vulnerable person who is under eighteen (18) years of age, or who, by reason of advanced age or other physical or mental condition is vulnerable to abuse, neglect or misappropriation of property and who was, at the time of such determination, in the care of:
    1. A state agency;
    2. An entity which is licensed or regulated by a state agency; or,
    3. An entity under the provisions of a contract between that entity and a state agency.
    Allegations of abuse, neglect, or misappropriation of personal property against individuals are investigated thoroughly. Due process is afforded to all accused persons before placement is made.
  5. License verification.
  6. Employment histories.

A student whose CBC shows negative findings, including the following, may be excluded by the healthcare facility from a clinical placement program:

  1. History of any felony conviction within the last seven years
  2. History of class "A" misdemeanor conviction within the last seven years
  3. History of class "B" misdemeanor conviction within the last seven years
  4. Listing on the registry maintained by the Department of Health pursuant to T.C.A. Section 68-11-1004
  5. Listing on any of the following registries: HHS/OIG list of excluded individuals, GSA list of Parties Excluded from Federal Programs, U.S. Treasury, Office of Foreign Assets Control (OFAC), List of Specialty Designated Nationals (SDN),
  6. An encumbered license (current or prior) in a health-related field.

The background check vendor will provide a report of the above eligibility screens to the designated UTHSC official (s) for each student.

PROCEDURE

  1. All applicants to programs at UTHSC must complete a Criminal Background Check as part of the on-line application process or, in cases in which the application process has involved an application service such as MCAS or PCAS, the CBC must be completed 6 months prior to matriculation.
  2. Students will be referred to the Tennessee Hospital Association (THA) website (http://www.tha.com/) and will click on “Student Background Checks”.
  3. The students will access the THA website and electronically complete the online process for initiating the background screening which includes:
    1. Posting his/her biographical information for the past seven years,
    2. Electronically signing the “Disclosure & Authority to release Information” Form, and
    3. Making payment by electronic bank transfer or credit card.
  4. The order will subsequently be processed by the private company. The company will:
    1. Manually enter data to request county criminal searches based on the past seven years of residency and ID Plus search results, OIG, Tennessee Abuse Registry, and verification of licensure, Certification or Designation, and employment verification,
    2. Complete the background check,
    3. Compare and note any discrepant information,
    4. Deliver the reports as agreed upon completion.
  5. A summary report will be sent to UTHSC displaying only the following limited information:
    1. The student’s demographic information,
    2. The type of verification ordered,
    3. Color-coded: GREEN = No discrepancies, YELLOW = Pending or undetermined records, and RED = Convictions on criminal searches or disqualifying results on all other verifications.
  6. When the summary report is coded GREEN, UTHSC will add that information to the student’s file and notify the student’s healthcare site that the student has received a clear (Green) rating from the private company. If the health care site requires additional information or investigations, either UTHSC or the healthcare site will notify the student.
  7. When a summary report is coded either RED or YELLOW, the Academic and/or Admission Dean of the respective UTHSC college will notify the student by telephone and in writing that the student must schedule an appointment to review the results of his/her background check. It will be necessary for the student to bring the complete, detailed copy of the report and all correspondence from the private company that conducted the CBC to the appointment. The student and the Academic and/or the Admissions Dean will meet to solicit additional information or appropriate explanation of the code.
  8. Additional background checks may be required by clinical affiliates prior to student entry into their sites. Students may bear the cost of these additional background checks.

CHALLENGED RESULTS:

  1. Students who question the accuracy of the report should immediately send a brief written statement as to the area they believe to be incorrect to the private company that performed the CBC,
  2. Re-verification will be made if the company determines that reasonable grounds exist and that the request is not frivolous or irrelevant,
  3. If parts of the report are deleted or changed because of re-verification, UTHSC and the student will receive a corrected report,
  4. If the student does not challenge the RED or YELLOW results from the private company that conducted the CBC and when the CBC findings are such that the student does not meet the healthcare site’s CBC requirement, UTHSC enrollment and or participation in all clinical rotations may be denied.

If a prospective student is denied admission to a program or if a current student is denied participation in clinical rotations due to CBC findings, the student will be notified by certified letter from the appropriate Dean (Academic or Student Affairs) of the respective college explaining why the student cannot matriculate or continue in the program.

All disputes pertaining to the CBC findings must be communicated in writing directly to the private company that conducted the CBC.

PDF version

Approval Date

February 12, 2013 (revised)
September 15, 2005 (approved)

Group

Committee on Academic and Student Affairs

Next Scheduled Review

February 2016

Office of Responsibility

Student Affairs