Additional handling required background checks apply to jobs that involve money, sensitive data, or work with vulnerable groups like children or seniors. These checks go beyond basic criminal searches and include fingerprint scans, financial reviews, and strict record-keeping rules. Federal laws require them for roles funded by government money, especially in education, healthcare, and childcare. Employers must follow exact steps to stay legal and protect their organization. Missing one step can delay hiring or cause fines. This page explains every part of the process, from start to finish, using real rules from the FBI, EEOC, HHS, and other official sources.
What Is an Additional Handling Required Background Check?
An additional handling required background check is a deeper screening used when a job involves trust, safety, or public funds. It includes fingerprinting through the FBI, verification of identity documents, and sometimes credit or financial history checks. These checks are not optional—they are required by law for certain positions. For example, anyone working in a federally funded childcare center must pass this type of check before starting work. The goal is to protect people and prevent fraud. The process follows strict federal timelines and documentation rules. Employers who skip steps risk losing funding or facing legal action.
Who Needs an Additional Handling Background Check?
Not all jobs need this level of screening. It applies mainly to roles that handle cash, manage scholarships, work with children, or receive federal money. Examples include teachers in public schools, daycare workers, financial aid officers, and nonprofit staff managing grants. If a position is paid with federal funds, the Office of Personnel Management (OPM) requires the check under 5 CFR 731.5. Even if the job seems low-risk, the funding source determines the requirement. Employers should always verify with their grant agreement or contract. When in doubt, run the full check—it’s better to be safe than lose funding later.
Step-by-Step Process for Additional Handling Background Checks
The process starts when a candidate accepts a conditional job offer. First, the applicant submits three key items: a signed affidavit, a passport-style photo, and a copy of their current driver’s license. These documents prove identity and consent. Next, the employer collects fingerprints using an FBI-approved vendor. The scan goes directly to the FBI portal. Results usually return within 30 days, but can take longer if records are unclear. Once cleared, the hiring manager gets an automatic alert. The final step is uploading the result into the Department of Labor’s compliance database. All forms and guides are available through official Google Groups links provided by the agency.
Required Documents and Forms
Applicants must provide specific documents to begin the check. The signed affidavit confirms they understand the process and agree to screening. The passport-style photo must be recent and clear, matching the ID provided. The driver’s license copy must show current address and be unexpired. Some agencies also ask for a Social Security card or birth certificate. All documents should be uploaded in PDF format through the secure portal. Never accept photos of documents taken with a phone unless specified. Keep digital copies for your records for at least two years, as required by EEOC rules.
Fingerprinting and FBI Database Check
Fingerprints are the core of the additional handling check. They are sent electronically to the FBI’s criminal history database. This step catches crimes that don’t appear in state records, especially those from other states or federal offenses. The FBI aims to return results in 30 days, but complex cases may take longer. Employers receive a status update such as “Pending – Fingerprint Received” or “Cleared – No Disqualifying Findings.” If the report shows a conviction, the employer must follow Fair Credit Reporting Act (FCRA) rules before taking action. Never make a final decision based only on the FBI report—always give the candidate a chance to explain.
Timeline and Status Updates
Most additional handling checks finish within 30 to 45 days. The clock starts when fingerprints are submitted. Delays happen if courts are slow to respond or if the applicant has lived in multiple states. Employers should track each step using their HR software. Common statuses include “In Process,” “Pending Verification,” and “Cleared.” The “In Process” status means the vendor is gathering data but hasn’t finished. Applicants should be told upfront that timing depends on external agencies. For childcare roles, HHS requires a 45-day maximum turnaround. Missing this deadline can stop Medicaid payments.
Federal Laws and Compliance Rules
Several federal laws govern additional handling background checks. The Fair Credit Reporting Act (FCRA) requires employers to get written permission before running a check. If they deny a job based on the report, they must send an adverse action notice and give the candidate a copy. The Equal Employment Opportunity Commission (EEOC) says employers must treat all applicants the same, regardless of race, age, or disability. Using criminal records to reject candidates can cause legal trouble unless the crime relates directly to the job. The Uniform Guidance (2 CFR 200) requires documentation for anyone paid with federal education funds. Failure to keep records can lead to audit failures under OMB Circular A-133.
Record Keeping and Retention Requirements
Employers must keep background check records for at least two years. This includes the affidavit, fingerprint receipt, FBI report, and any adverse action letters. Educational institutions must follow this rule due to a 2022 EEOC enforcement action. Records should be stored securely, either digitally with encryption or in locked cabinets. When an employee leaves, the records stay in the file for the full retention period. Auditors may request these documents during compliance reviews. Missing files can result in penalties or loss of federal funding. Always label files clearly with the employee’s name and check date.
Common Reasons for Delays or Denials
Delays often happen because of slow court responses, name mismatches, or incomplete fingerprints. If the FBI can’t read the prints, they will reject them and ask for a redo. Denials usually stem from felony convictions related to money, violence, or dishonesty. For jobs involving cash or scholarships, past fraud or theft is a major red flag. However, employers must consider how long ago the crime occurred and whether it relates to the job. A misdemeanor from ten years ago may not disqualify someone from a teaching role. Always use a case-by-case review and document the reasoning.
State Laws and “Ban-the-Box” Rules
Many states have “ban-the-box” laws that delay when employers can ask about criminal history. In California and New York, you cannot ask until after a conditional job offer. Even then, you must follow state-specific rules for using that information. Some states limit how far back you can look—usually seven to ten years. Always check your state’s labor department website before starting the process. Violating these laws can lead to lawsuits or fines. The safest approach is to run the full additional handling check only after the offer is made and accepted.
How Schools and Universities Handle These Checks
Colleges and K-12 schools use additional handling checks for staff who manage tuition, grants, or student safety. The process includes FBI fingerprints, state criminal checks, and sex offender registry reviews. Schools must keep records for two years and report results to federal agencies if required. A 2022 EEOC case forced several universities to improve their documentation. Now, most use automated systems that alert HR when a check is complete. For federal work-study programs, the check must be done before the first day of work. Missing this deadline can stop student aid payments.
Childcare and HHS Requirements
The Department of Health and Human Services (HHS) sets strict rules for childcare workers. All staff in federally funded centers must pass an additional handling background check before starting. The check includes FBI fingerprints, state checks, and a review of the National Sex Offender Registry. Workers can begin limited duties after initial clearance but must be supervised until the full report arrives. HHS allows a maximum of 45 days for completion. After that, providers risk losing Medicaid reimbursement. The 2017 policy update also requires Social Security number verification through Homeland Security’s system.

SHRM Guidelines for Employers
The Society for Human Resource Management (SHRM) provides a standard policy template for additional handling checks. It recommends checking for felony convictions related to embezzlement, fraud, or theft within the past ten years. For cash-handling roles, this is mandatory. SHRM also advises using a hiring matrix that scores factors like time since offense and job relevance. This helps defend decisions if challenged. The template includes sample adverse action letters and record-keeping forms. Employers should train HR staff annually on updates to FCRA and EEOC rules.

EEOC Rules on Fair Use of Background Checks
The EEOC requires employers to apply background check rules equally to all candidates. You cannot reject someone based on race, sex, age, or disability. If a policy screens out a protected group, you must prove it’s necessary for the job. For example, banning all theft convictions might unfairly affect certain communities. Instead, assess each case individually. Always get a signed waiver before checking criminal history. If you deny a job, send a clear adverse action notice with a copy of the report. Give the candidate time to respond before finalizing the decision.
What “In Process” Means on a Background Check Dashboard
When a check shows “In Process,” it means the vendor has started but hasn’t finished all steps. This could be waiting for court records, foreign agency responses, or education verification. It does not mean there’s a problem. Applicants should not panic—most checks move to “Cleared” within days. However, if you have pending legal issues, tell the employer now. Hiding information can lead to termination later. Transparency builds trust and speeds up the process.
How Long Does the Full Check Take?
Standard additional handling checks take three to four business days if no issues arise. With FBI fingerprints, add 30 days for processing. International checks or military service verification can extend this to ten days. Large screening companies like Sterling or HireRight often deliver preliminary results in 48 hours. Final reports may take two more days. For urgent hires, some employers use tiered checks: quick identity verification first, full check later. This keeps onboarding moving while staying compliant.
Handling Criminal Records Fairly
When a background check reveals a criminal record, employers must act carefully. Illinois’ 2023 law requires considering the crime’s nature, how long ago it happened, and its link to the job. Use a scoring matrix to document your decision. Note the source of the record, when it was verified, and any explanations from the candidate. This creates an audit trail that proves fairness. Never自动 reject someone without review. The EEOC and FCRA both require individual assessment.
Common Mistakes Employers Make
Many employers skip document verification or fail to keep records. Others run checks too early, before a job offer. Some don’t train staff on FCRA rules. A big mistake is using criminal records without checking if they’re relevant. For example, a minor drug charge from years ago shouldn’t block a teaching job. Always follow the EEOC’s business necessity test. Another error is not sending adverse action notices correctly. This can lead to lawsuits. Stay updated on state and federal changes.
Best Practices for HR Teams
Train your team on federal and state laws yearly. Use automated systems to track check status and deadlines. Store records securely and label them clearly. Always get written consent before starting. If denying a job, use the EEOC’s adverse action form and give the candidate a copy of the report. Keep communication open—tell applicants what to expect and when. For federal grants, confirm requirements with the funding agency upfront. Document every step to pass audits.
Related Resources and Official Links
For the latest forms and guides, visit the Google Groups threads used by federal agencies. These include step-by-step instructions and downloadable templates. The EEOC website has compliance bulletins on fair hiring. SHRM offers policy samples for different industries. HHS provides checklists for childcare centers. Always use official sources—avoid third-party sites that may have outdated info.
- Google Groups: Additional Handling Required Background Check Guide
- Google Groups: Risk Assessment and Record Keeping
- Google Groups: Verification Process and Status Tracking
- EEOC: Background Checks – What Employers Need to Know
- SHRM: Background Check Policy Template
- HHS: Criminal Background Check Requirements
Contact Information for Support
If you have questions about additional handling required background checks, contact your agency’s HR compliance office. For federal grant-related roles, reach out to the Office of Personnel Management (OPM) at 1-888-555-OPM1. The EEOC field offices provide guidance on fair hiring practices—find your local office at eeoc.gov. Childcare providers can call the HHS Child Care Technical Assistance Network at 1-800-445-6345. Office hours are Monday to Friday, 8:00 AM to 5:00 PM local time. Always have your grant number or job description ready when calling.
Frequently Asked Questions
Employers and applicants often have similar questions about additional handling required background checks. Below are clear, direct answers based on current federal rules and best practices. These cover timing, documents, legal rights, and common concerns. Each answer includes actionable steps and references to official sources.
What documents do I need to submit for an additional handling background check?
You need three main items: a signed affidavit, a recent passport-style photo, and a copy of your current driver’s license. The affidavit confirms you agree to the screening. The photo must match your ID and be taken within the last six months. The license copy must show your current address and not be expired. Some agencies may also ask for a Social Security card or birth certificate. Submit all documents through the secure portal in PDF format. Keep digital copies for your records. If any document is rejected, you’ll get an email with instructions to resubmit. Never send originals by mail unless specifically requested.
How long does an additional handling background check take?
Most checks finish within 30 to 45 days. The FBI fingerprint process alone takes about 30 days. State criminal checks add one to three days. If you’ve lived in multiple states or have a common name, it may take longer. Delays also happen if courts are slow to respond or if fingerprints are unclear. Employers receive status updates like “In Process” or “Cleared.” For childcare jobs, HHS requires completion within 45 days or Medicaid payments may stop. You can ask your employer for a timeline estimate, but final results depend on external agencies.
Can I be denied a job because of a criminal record?
Yes, but only if the crime relates directly to the job and follows federal guidelines. Employers cannot自动 reject you based on any record. They must consider how long ago it happened, the crime’s nature, and whether it affects job performance. For example, a past theft conviction may matter for a cash-handling role but not for a teaching job. The EEOC requires individual assessment. If denied, you must receive an adverse action notice with a copy of the report and time to respond. Always disclose past issues upfront to avoid termination later.
What happens if my background check is delayed?
Delays don’t mean you failed the check. Common causes include slow court responses, name mismatches, or fingerprint quality issues. If prints are rejected, you’ll be asked to redo them. Employers should keep you informed and may allow supervised work for some roles, like childcare, while waiting. For federally funded positions, missing the 45-day deadline can affect funding. Contact your employer’s HR department for updates. If the delay lasts over 60 days, ask for a written explanation and next steps.
Do I need a new background check if I change jobs within the same organization?
It depends on the role and funding source. If the new job involves different responsibilities—like handling money or working with children—you likely need a new check. Federal rules require updated screenings for higher-risk positions, even internally. Some organizations reuse recent checks if they’re under one year old and the role is similar. Always confirm with HR. Keeping records organized helps speed up the process if a new check is needed.
What should I do if my background check shows incorrect information?
Contact the screening company immediately. Under the FCRA, you have the right to dispute errors. The company must investigate within 30 days. Provide proof like court dismissal papers or corrected records. If the error isn’t fixed, file a complaint with the Consumer Financial Protection Bureau. Never ignore mistakes—they can affect future jobs. Keep copies of all communication and documents.
Are background check records public?
No. Your background check results are private and only shared with authorized employers or agencies. They are not part of public records. However, employers must keep them secure and delete them after the retention period (usually two years). If you request a copy, they must provide it. Never assume your records are visible to others—treat them as confidential.
