The childcare background-check process for employers, step by step

Start from the federal floor.

Under the Child Care and Development Block Grant (CCDBG) background-check rules at 45 CFR 98.43 — the federal CCDF rules of the U.S. Department of Health and Human Services' Administration for Children and Families (ACF) — every child care staff member of a licensed, regulated or registered provider, and of any provider eligible for CCDF subsidy, must have a comprehensive background check.

The comprehensive check has these components:

• An FBI fingerprint check, run through the FBI's Next Generation Identification system.
• A search of the National Sex Offender Registry (the NCIC).
• State criminal repository, state sex offender registry and state child abuse and neglect registry checks — for the current state and for every state the person lived in during the past 5 years. The state criminal repository check requires fingerprints in the state of residence.

The interstate part is easy to undercount: it reaches each state where the staff member lived during the preceding 5 years, so a candidate who has moved between states brings a multi-state request with them.

And the request has to come first — under the federal rules the checks are requested before the person becomes a staff member, which means the submission, not the first shift, starts the state's clock.

Cast the net wide enough.

The CCDF definition of "child care staff member" covers anyone employed by a provider for compensation, including contract employees and self-employed individuals — staffing-agency temps and contracted substitutes need the same checks as your directly hired teachers.

In a family child care home the rule reaches further still: every household member age 18 or older counts as a staff member needing checks.

Head Start grantees run on a separate rule.

Current Head Start standards at 45 CFR 1302.90 require, before hire, an interview, reference checks, a sex offender registry check and either a state or tribal or an FBI fingerprint check; the remaining check and the child abuse and neglect registry check must be completed within 90 days, with no unsupervised access to children until then, and a full re-check every 5 years.

ACF's August 7, 2026 proposed rule would remove the standards' own background-check procedures — statutory requirements and state CCDBG-aligned checks would still apply — and it is a proposal, not a final rule, so check its current status before relying on the 90-day structure.

A Head Start standard does not transfer to a private center; a private center's floor is the CCDF rule.

Confirm before you hire: the components above are the federal minimum.

States may disqualify for offenses beyond the federal list, and your state's published procedure governs how the components are ordered and returned — read your state's current policy, and confirm it with your state child care licensing agency, before you make an offer.

For where the check sits in the license itself, see daycare license requirements.

Each state must publish its background-check policies and how to submit a request on its website — which makes the state site, not a national vendor's page, the authority on where and how your candidates get fingerprinted.

Fingerprinting locations and vendors are state-specific, so pull the current instructions from your state child care licensing agency before you write anything about checks into your onboarding packet.

The sequence, in the order the work arrives:

1. Collect consent first. Refusing to consent to the check is itself a federal mandatory disqualifier, so the signed consent belongs at the top of the pre-start checklist — before the appointment, not after it.
2. Submit the request before the first day. The request precedes employment, and submitting it is what starts the state's 45-day completion window.
3. Schedule the fingerprint appointment. The state criminal repository check requires fingerprints in the state of residence, so a candidate who has just moved needs an appointment in their new state — a check run in the old state does not stand in for the new state's requirement.
4. Track the interstate requests. The check reaches every state the person lived in during the past 5 years; how those out-of-state requests are made is defined in your state's published process.

Build the appointment into your start-date math.

The 45-day clock runs from submission, so a late fingerprint appointment eats the window before any check has run — book it at offer acceptance, not the week before the start date.

The federal clock: states must complete a background-check request as quickly as possible and within 45 days of submission.

Caring for Our Children Basics — ACF guidance dated July 2025 — states the same benchmark: screenings completed within 45 days, as quickly as possible.

What you get back at the end is narrower than a report: the employer receives an eligible or ineligible statement, not the underlying offense.

The worker is the one who gets the details, along with information on how to appeal; states must offer an appeal process and written notice of the decision.

One qualifying result starts the job.

Under 45 CFR 98.43(d)(4), a new hire may begin work after a qualifying result on either the FBI fingerprint check or the in-state fingerprint check — but until every component clears, someone with a qualifying background check must supervise them at all times.

That is the federal floor, not a promise of uniformity: states may be stricter, and some bar any work with children before full clearance.

Confirm the rule your state enforces with your state child care licensing agency before you staff a room around a partial result.

Practically, the 45-day window shapes your scheduling more than your hiring.

Submit on signing, plan the first weeks of any new schedule around supervised coverage, and don't build a solo shift for anyone whose file still has a component pending.

You do not always have to re-run a check for someone who already cleared — but only within your state.

Under the federal portability rule, a new provider need not re-run a check when the worker received a qualifying result within the past 5 years while working for, or applying to, another provider in your state, and has not been separated from in-state child care employment for more than 180 consecutive days.

Both conditions have to hold: the result date and the employment continuity.

Portability stops at the state line.

A clearance earned in another state does not transfer; the checks covering every state your candidate lived in during the past 5 years are components of the new check itself.

If you accept a portable clearance, document what makes it portable — the date of the qualifying result and the evidence that the gap in in-state child care employment stayed within the 180-day limit.

Your state's published policy governs how portability is claimed and recorded, so confirm the mechanics with your state agency rather than with the candidate's recollection of them.

Clearance is not one-and-done.

Under the CCDF rules, checks must be requested before a person becomes a staff member and repeated at least once every 5 years; Caring for Our Children Basics states the same rhythm — screened on employment, and at least every 5 years after that.

The request is the provider's to make, and it covers the temp from the staffing agency on the same cycle as your lead teacher, because the staff-member definition does not distinguish between them.

What keeps the cycle honest is the file you keep on each person: when the request went in, which components have cleared and which are still out, what the eligible or ineligible statement said, and when the 5-year recheck falls due.

For anyone you accepted on portability, add the result date and the employment-continuity evidence behind the 180-day rule.

For anyone who started on a single qualifying fingerprint result, add who supervised them and until which component cleared.

The check is one gate in the hiring sequence, not the whole of it — the rest of hiring for your childcare center, from the posting to onboarding, lives in the hub.

The fee side has one firm federal rule: background-check fees charged by a state may not exceed the actual cost of processing and administration.

The cap is the only federal figure — the amount is set state by state, and the number that counts is the one your state publishes.

Who pays is not settled by the federal rule.

The cap limits what a state may charge; it does not assign the cost to the center or to the new hire, and our research did not verify a national norm on which side usually absorbs it.

Your state's published policy tells you what the check costs; your own policy decides who pays it.

Decide the who-pays question before you post the role and put it in the offer — a background-check fee that surfaces after the start date is a bad first payroll conversation.

Whatever you decide, the confirmation loop is the same as everywhere else on this page: your state publishes its background-check policies and the request process on its website, so get the current fee and timeline from your state child care licensing agency (and your state's CCDF Lead Agency, where subsidy is involved).

This page is employer information, not licensing or legal advice. Each state publishes its background-check policies and request process on its website — confirm the current process, fees, timelines and disqualifiers with your state child care licensing agency and, where subsidy is involved, your state's CCDF Lead Agency before you hire.