The following is from UAMS College of Health Professions Student Affairs Policy 02.12.02 (revised Oct. 13, 2021).
Purpose
The purpose of this policy is to establish guidelines and procedures for conducting criminal background check(s) and drug screens for applicants who have been offered admission or students enrolled in a College of Health Professions program.
The policy is adopted because it is incumbent on the College of Health Professions to:
- Meet contractual obligations contained in affiliation agreements between the college and clinical education affiliates
- Exercise due diligence and assess the qualifications of all individuals who may have contact with patients and/or research participants
- Ensure compliance with clinical education affiliate standards and regulations pertaining to human resource management
- Meet public demands for greater diligence in light of the national reports on injuries and deaths resulting from medical malpractice and medical errors
Applicability
This policy applies to the following:
- All applicants who have been offered admission into a College of Health Professions program
- Enrolled students who may be required to obtain additional background checks and drug screens following matriculation
Exemptions
Students enrolled in 100% online programs without clinical placements and pre-degree / non-degree / non-certificate students will be exempt from obtaining a criminal background check and drug screening.
Policy
When required, admitted applicants or students must obtain a criminal background check and drug screen from a vendor approved by the College of Health Professions. The results of the background check and drug screen must be deemed satisfactory as a condition of the student’s admission or continuation in the program. Admission may be denied based on the results of the background check or drug screen. Only students with satisfactory results will be allowed to register for classes.
At times, a currently enrolled student may be required to obtain an additional background check and/or drug screen for a variety of reasons, e.g., clinical affiliate requirements, contradictory findings from a clinical affiliate’s background check, suspicion or reports of violation of laws, etc. In those instances, currently enrolled students will be barred from participating in clinical education experiences at clinical affiliates until a background check and/or drug clearance is obtained. Failure to obtain an additional background check and/or drug clearance may be cause for suspension or dismissal from the program.
Scope of Background Checks
Background checks typically include the following criteria and cover the past seven years:
- Social Security Number verification
- Criminal search, including felonies, Class A, Class B and Class C misdemeanors (seven years)
- Violent Sexual Offender and Predator Registry search
- Office of the Inspector General List of Excluded Individuals/Entities
- General Services Administration List of Parties Excluded from Federal Programs
- U.S. Treasury, Office of Foreign Assets Control, List of Specially Designated Nationals
- Applicable State Exclusion List
Note: The time period and the types of searches are subject to change without notice. Changes will be approved by the College of Health Professions Executive Committee.
Approved Vendor(s)
Background checks and drug screens must be conducted by a vendor approved by the College of Health Professions. Background check reports and drug screens from other sources will not be accepted.
Timing of the Background Checks and Drug Screen
An applicant offered admission must obtain a background check and drug screen prior to enrollment into a College of Health Professions program. Background checks must be completed no more than six months before matriculation.
Cost of Background Checks and Drug Screens
The applicant or student will pay the cost of required background checks and drug screens.
Period of Validity
A background check and drug screen is honored for the duration of enrollment if the student is continuously enrolled; however, particularly in programs longer than one year in length, a clinical affiliate may require a student to submit an updated background check and/or drug screen. The student will pay the cost of the required update and must use the college’s approved vendor.
A student who has a break in enrollment is required to complete a new background check and drug screen. A break in enrollment is defined as non-enrollment of at least one semester in the approved curriculum of the degree program. An officially approved leave of absence is not considered a break in enrollment. During enrollment, students are subject to “for cause” drug screens and/or additional background checks (due to suspicion or reports of violation of laws, etc.) and the results must be deemed satisfactory in order to continue in the program.
Significant Findings in Background Checks
Re-Verification
An applicant or student has the right to request that the vendor who performed the background check re-verify that the background check is correct. Any costs associated with the re-verification will be paid by the applicant or student. The college may require the applicant or student to produce additional documentation to verify or re-verify findings.
Evaluation of Significant Findings
If significant findings are reported in a background check, the applicant or student may be referred to the specific program or discipline’s professional licensing board to obtain clearance. The College of Health Professions will concur with the licensing board’s decision.
If the professional licensing board does not review significant findings, the dean or dean’s designee will review the findings in consultation with the department chair and make a recommendation to the program as to whether an applicant should be admitted or if a current student should be able to continue in the program.
False or misleading information supplied by the applicant or student, or omission of required information with regard to a background check, will result in one of the following:
- Rescindment of an offer for admission
- Dismissal from the certificate or degree program
Adverse Actions Based on Background Checks
Consistent with the Fair Credit Reporting Act, if an applicant is denied admission or if an adverse action is taken against an enrolled student, based on findings of a background check (e.g., denial of participation in clinical education experiences, dismissal, or suspension), the applicant or student will be informed:
- How to obtain a copy of the background check report
- How to contact the vendor to challenge the accuracy of the report
- That the vendor was not involved in the decision that resulted in the adverse action
Appeal Procedures for Enrolled Students
Ordinarily, a student who is unable to complete clinical education experiences will be unable to complete the degree program, and the student may withdraw or be dismissed from the program. Therefore, a student who is denied participation in clinical education experiences because of significant findings on a background check may request consideration following the College of Health Professions Grievance Procedures.
Deferred Matriculation or Participation
If a background check reveals matters that may be cleared by the applicant or student, matriculation or continuation in the degree program may be deferred up to one year while the matter is being resolved.
Drug Screens
Results of the drug screen must be deemed satisfactory as a condition of the student’s admission or continuation in the program. The admitted applicant or student will pay the cost of the required drug screen. Students enrolled in 100% online programs without clinical placements and pre-degree / non-degree / non-certificate students will be exempt from obtaining a criminal background check and drug screening.
Approved Vendor(s)
Drug screens must be conducted by a vendor approved by the College of Health Professions.
Confidentiality and Disposition of Reports
Drug screen reports are maintained securely, confidentially, and separately from other academic files in the office of the dean for a period of time established by guidelines or policy.
Additional Drug Screens
Students may be asked to complete a drug screen “for cause” at any time during enrollment. Clinical placements may require additional drug screens for which the student is responsible for the cost. Enrolled students may be barred from participating in clinical education experiences at clinical affiliates if drug screen results are not satisfactory. Failure to obtain a requested drug screen may be cause for suspension or dismissal from the program.
Confidentiality and Disposition of Background Check Reports
Background check and drug screen reports are maintained securely, confidentially, and separately from other academic files in the office of the dean for a period of time established by guidelines or policy.
Approval
This policy was approved by the College of Health Professions Executive Committee on June 14, 2012.