Head Start background check requirements for grantees

Head Start's pre-hire screening comes from the Head Start Program Performance Standards, the rules the Office of Head Start at the Administration for Children and Families (ACF) administers.

The relevant section is 45 CFR 1302.90(b), and it applies before a person is hired, directly or through contract, including transportation staff and contractors.

Four things have to happen before that first day:

• An interview with the candidate.
• References verified.
• A sex offender registry check.
• A fingerprint criminal history check — either a state or tribal check, or an FBI check.

The fingerprint line is an either/or at this stage: one of the two results has to be in hand before hire, and the other fingerprint check is among the items completed after hire under the 90-day window covered below.

So the paperwork trail that matters on day one is interview notes, the reference file, the registry result and the fingerprint report you already hold.

Keep the rule's scope in mind.

This is a Head Start standard, and a Head Start standard does not transfer to a private center — a center that is not a Head Start grantee hires under its state's rules and the federal CCDF background-check rule, which is the background-check process we walk through separately.

The CCDF rule is not only for private centers, though: it covers every child care staff member of a licensed, regulated or registered provider, so if your Head Start program operates as one, those checks apply alongside 1302.90(b).

The check is also only one of the Head Start staffing rules; the qualifications each role needs sit in that companion guide.

A Head Start program has 90 days after an employee is hired to complete the background check process.

That is the room 1302.90(b) allows to trail past the first day: the remaining fingerprint check — whichever of the state or tribal and FBI checks did not come back before hire — and the child abuse and neglect state registry check, where a state registry is available to query.

The hard line is unsupervised access. A new hire may not have unsupervised access to children until the full background check process is complete.

Build the first 90 days around that: pair the new teacher with fully cleared staff, and keep solo coverage — a lone nap room, a closing shift by themselves — off the schedule for anyone whose file is still open.

The 90-day structure is Head Start's own.

The parallel question for private centers — whether a childcare employee can start at all while checks are pending, and under what supervision — follows the CCDF rules, which also reach a Head Start program that is a licensed, regulated or registered provider, and our guide to working before the background check clears covers it.

Hiring is not the only trigger.

A Head Start program must conduct the complete background check for each employee, consultant, or contractor at least once every five years — the complete check, not a shortened run of one or two components.

That cadence is easy to lose across a large staff list, so track a recheck due date for each person next to their hire date, and include the consultants and contractors who have been with the program for years.

A lapsed recheck is invisible in a classroom but easy to catch in a file — the date is either current or it is not.

One caveat belongs here. In August 2026, ACF published a proposed Head Start rule that would drop the Performance Standards' own background-check procedures — the 5-year re-check is one of its examples — on the reasoning that statutory requirements and state CCDBG-aligned background checks would still apply.

A proposal is not a final rule: as of October 2026, the five-year recheck is the current standard.

Follow the rulemaking and confirm the current requirement with the Office of Head Start before you rebuild your compliance calendar around either version.

The standards reach well past directly hired teachers.

The before-hire requirements apply to a person hired "directly or through contract, including transportation staff and contractors" — so a contracted bus driver and a classroom aide supplied through a contract both have to clear the same interview, reference, registry and fingerprint requirements before their first day.

The five-year recheck is written just as broadly: it covers each employee, consultant, or contractor, which pulls itinerant consultants into the same cycle as your classroom staff.

Volunteers are the open edge.

The requirements our research verified cover employees, consultants, contractors and transportation staff; they do not settle how volunteers are screened under the standards, and this page will not guess at it.

Treat the gap as a question to ask, not an exemption to assume: confirm with the Office of Head Start how volunteers should be checked before someone spends unsupervised time with children in your program.

This page is employer information, not licensing or legal advice. Head Start background-check requirements are administered by the Office of Head Start under 45 CFR 1302.90 — confirm the current requirements, and the status of any proposed changes, with the Office of Head Start before you make hiring decisions, and check the state background-check rules that also apply to licensed programs with your state child care licensing agency.