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February 08, 2013
Governor Deval Patrick recently signed into law House Bill (HB) 4307, legislation that requires Massachusetts schools to conduct national criminal background checks on all employees. Prior law allowed school districts to conduct only name-based Criminal Offender Record Information (CORI) checks, which are limited to crimes committed in Massachusetts.
Under the new law, all newly hired teachers, school employees, bus drivers, subcontractors commissioned to perform work on school grounds, and other education and childcare providers must undergo fingerprint-supported state and national background checks before the start of the 2013–2014 school year. All current employees must undergo national background checks over the next 3 years, before the start of the 2016–2017 school year.
In addition, the law gives investigators at the Massachusetts Department of Early Education and Care (EEC) and the Department of Elementary and Secondary Education (ESE) access to state and federal criminal record checks.
The bill requires employers of licensed educators to share with the ESE any information, including the results of background checks, which might be relevant to an investigation of alleged misconduct by a license holder or applicant. It also requires all of the following to undergo a national criminal history record check:
- Individuals who hold an EEC program license or teacher qualification,
- Employees in an EEC-licensed or approved program,
- Family childcare providers, their household members (aged 15 or older), and anyone who is regularly on the premises, and
- Individuals in an EEC-licensed or approved program who have the potential for unsupervised contact with children.
The new law will “better protect both children and adults in schools and early education and care settings across the Commonwealth,” said Education Secretary Paul Reville.
Associated Press / January 11, 2013
New Mass. law requires fingerprinting teachers
FEDERAL UPDATES 2nd Q 2011
FTC Issues New Guidance on the Fair Credit Reporting Act
The Federal Trade Commission (FTC) has issued a new staff report comprehensively updating its guidance under the Fair Credit Reporting Act (FCRA). In 1990, the FTC issued a commentary on the
FCRA (published as an appendix to 16 CFR part 600). Between 1997 and 2001, it issued informal opinion letters in response to selected questions that it received. Changes to the FCRA, primarily in
1996 and 2003, rendered much of the prior commentary obsolete. The new guidance reflects the FTC’s most up-to-date guidance. Additionally, the FTC has formally withdrawn its prior commentary. In a
press release, the FTC notes that the reason for this is that the recent financial reform legislation transferred the FTC’s authority to issue this kind of guidance to the newly created Consumer
Financial Protection Bureau. The FTC says that the new guidance mostly codifies its prior positions, but that it modifies some of its prior interpretations. Therefore, there may be new regulatory
positions set out in the 117-page document.
Please see below for links to the documents referenced in this update:
- The report is available at http://ftc.gov/os/2011/07/110720fcrareport.pdf.
- The withdrawn commentary is available at http://www.gpo.gov/fdsys/pkg/CFR-2010-title16-vol1/pdf/CFR-2010-title16-vol1-part600-app-id1020.pdf.
- The informal staff opinion letters are available athttp://www.ftc.gov/os/statutes/fcra/index.shtm.
- The formal withdrawal of the prior commentary is available athttp://ftc.gov/os/fedreg/2011/07/110720fcrafrn.pdf.
- The FTC’s press release is available at http://ftc.gov/opa/2011/07/fcra.shtm.
FTC Says Screening of Volunteers is for Employment Purposes Under the FCRA
In its newly issued staff report that updates its guidance under the Fair Credit Reporting Act (FCRA), the Federal Trade Commission (FTC) says that the term employment purposes includes “a
nonprofit organization staffed in whole or in part by volunteers.” (See page 32 of the report.) The sources cited in the footnote for this assertion do not support it. The first source cited there
is Hoke v. Retail Credit Corp. in that case, the court construed the words employment, promotion, and reassignment in the definition of “employment purposes” have “specific
meanings in the area of activities for the production of income.” By definition, volunteering is not an activity for the production of income. The other two sources that the footnote cites,
the Allison and Solomon information staff opinion letters, both deal with cases in which the activity in question was income-producing (independent truck drivers
in Allison and title insurance agents in Solomon). However, courts often defer to the FTC’s guidance on matters under the FCRA. Therefore, anyone who screens
volunteers should consider immediately adopting the practices related to employment-purpose screening, including disclosure, authorization, and pre-adverse-action notices.
Please see below for links to the documents referenced in this update:
- The report is available at http://ftc.gov/os/2011/07/110720fcrareport.pdf.
- The Allison and Solomon opinion letters are available throughhttp://www.ftc.gov/os/statutes/fcra/index.shtm.
- Copies of the Hoke opinion can be found by searching the internet for the phrase “Hoke v. Retail Credit.”
April 23, 2011 /24-7PressRelease/ -- Study Finds Most Nursing Homes Have Employees With Criminal Convictions
According to a government report, more than 90 percent of nursing homes have employees with criminal records. The current patchwork system of criminal-background checks may contribute to the
high number of individuals with criminal convictions working in nursing homes, and it leaves vulnerable nursing-home residents at risk of harm.
Government Investigation
At a senator's request, the U.S. Department of Health and Human Services' Office of Inspector General investigated the number of individuals with criminal records working in nursing homes. To
conduct the investigation, the OIG selected a stratified random sample of 260 nursing homes from more than 15,000 Medicare-certified nursing homes and performed Federal Bureau of Investigation
background checks on the employees of those 260 nursing homes. Long-term care facilities like hospices were not investigated, and contract workers at nursing homes were also not
considered.
Criminals in Nursing Homes
The analysis revealed that, in 2009, 92 percent of the nursing homes employed at least one person with a criminal conviction. Further, almost half of the nursing homes employed five or more
people with criminal convictions. At one facility with a total of 164 employees, 34 employees had at least one conviction each, said Daniel R. Levinson, Inspector General of the U.S. Department of
Health and Human Services. Seven registered sex offenders were working at five different nursing homes, and 13 percent of the employees with criminal convictions were convicted of crimes against
people. Most of the employees' convictions, 44 percent, were for crimes against property such as shoplifting, burglary or writing bad checks.
Medicare and Medicaid Regulations
Federal regulations declare that nursing homes that receive Medicare and Medicaid payments cannot employ people convicted of "abusing, neglecting or mistreating" nursing-home residents and
cannot employ people entered in state nurse-aide registries for neglect, abuse or mistreatment of nursing-home residents, including theft of resident property.
The Centers for Medicare and Medicaid Services' guidelines state that nursing homes "must be thorough in their investigations of the past histories of individuals they are considering hiring."
However, criminal-background checks are not required by federal law. Individual states may create their own background-check standards, but the lack of centralized screening of nursing-home employees
puts nursing-home residents in danger.
Patient Safety Risks
Currently, only ten states require pre-employment state and FBI criminal-background checks. Because only the FBI background check reports criminal convictions in multiple states, someone with a
conviction in one state may find employment in a nursing home in a different state that does not use FBI criminal-background checks.
Senator Herb Kohl, D-Wisconsin, Chairman of the Senate Special Committee on Aging, said the present background-check system is "haphazard, inconsistent and full of gaping holes in many states.
Predators can easily evade detection during the hiring process, securing jobs that allow them to assault, abuse and steal from defenseless elders."
In addition, AARP spokesman Jim Dau said, "There are still potentially-dangerous gaps in the system used to determine who will be responsible for providing care for many people during
vulnerable points in their lives." Since nursing-home employees often work unsupervised in close contact with people who are less able to protect their property and defend themselves, a
background-check system -- or lack thereof -- that allows people with criminal convictions to slip through the cracks puts loved ones at risk for theft and, even worse, maltreatment or nursing-home abuse.
National Background Check Program
On March 23, 2010, President Barack Obama signed the Patient Protection and Affordable Care Act. According to the OIG report, the Patient Protection and Affordable Care Act requires the
Secretary of Health and Human Services to implement a nationwide program for individual states to conduct both state and FBI background checks for nursing-home employees with direct access to
nursing-home residents.
Because criminal convictions are sometimes under different names, the National Background Check Program will perform fingerprint-based searches of state and federal criminal-conviction records.
However, FBI records generally do not indicate whether the victim of a crime was a nursing-home resident. Therefore, additional information on a potential nursing-home employee's criminal conviction
is necessary.
Improvements to nursing-home employee screening should be made quickly so elderly and vulnerable residents are not harmed by people with criminal convictions. If you suspect that a relative or
loved one in a nursing home may be suffering neglect, abuse or maltreatment from nursing-home employees, contact an experienced nursing home attorney in your area to discuss your legal
options.
Article provided by Dansky | Katz | Ringold | York
Visit us at www.nursinghome-legalhelp.com