The purpose of this document is to set forth policies and procedures regarding student background checks. The William Jewell College (“College”) Nursing Department is committed to the health, safety and well-being of all patients cared for by its students as well as the students who participate in its programs and represent the College in clinical agencies. In order for these clinical agencies to gain or maintain accreditation with The Joint Commission (TJC), all employees, volunteers or students working at those entities must pass a criminal background check. Also, Missouri maintains a Family Care Safety Registry (“FCSR”) that contains background information on child-care, elder-care, mental-health and personal-care workers. Certain criminal violations or FCSR information can disqualify an individual from working in some health care fields. Thus, this policy ensures that the practices of the College conform to TJC’s accreditation requirements and that it is preparing students who will be qualified to enter their desired field.
Criminal background checks and FCSR reports are required of all students who have been conditionally accepted to the College’s Nursing Program. Students are responsible for completing criminal background checks and FCSR reports as described in the Procedures section below. A background check may be ordered as early as 5 months prior to start of the program. A criminal background check and FCSR report must be completed and the results provided to the Department of Nursing’s Clinical Compliance Coordinator no later than 20 days prior to the start of the student’s first nursing class. A student will have his/her conditional acceptance to the Nursing Program revoked if the results are not received by this deadline.
Results of a student’s criminal background check and FCSR report will be made available to the student and the Department of Nursing’s Clinical Compliance Coordinator; the results may also be shared with the Department of Nursing’s Chair and the appropriate personnel at a clinical agency site where the student is attempting to be placed.
A. Admission into the Nursing Program
A student will have his/her conditional acceptance to the Nursing Program revoked if the criminal background check shows any criminal convictions or pending charges (not including minor traffic violations) or the FCSR report shows any negative information (even if such information does not rise to the level of a criminal conviction).
B. Student Duty to Self-Report
Students who have completed an acceptable background check but have not started the program and students currently enrolled in the Nursing Program and engaged in clinical experiences have an ongoing duty to report any criminal convictions, pending charges, or other negative information that would show up on an FCSR report that arise during such enrollment.
C. Placement at Clinical Agencies
If a student has an unacceptable background check or FCSR report, or self-reports such information, subsequent to being enrolled in the Nursing Program, he/she will not be automatically expelled from the Nursing Program. However, the College may not be able to place a student with such results at a clinical agency for a clinical experience. For a student already placed, this information may result in the clinical site prohibiting the student from continuing in the clinical experience. If a student is unable to participate in a clinical experience for whatever reason, he/she will not be able to progress through the course of study required by the Nursing Program.
When a student who has had an unacceptable criminal background check or FCSR report attempts to be placed at a specific clinical site or wishes to continue at his/her current site, the appropriate personnel at the clinical site will evaluate the information and surrounding circumstances and, at their sole discretion, shall determine if the student can participate in a clinical experience at their site or continue on with his/her current placement at the site. The College makes no final decisions regarding student acceptability for a clinical placement or ability to continue on with a current placement based on the results of criminal background checks or FCSR reports.
D. No Representations Regarding Licensure and Employment
An acceptable criminal background check or FCSR report may be a prerequisite to taking the licensure exam or employment in a particular health care field. It is the student’s responsibility to know whether he/she will be eligible for licensure or if a conviction or other adverse information in a criminal background check or FCSR report will prevent him/her from being licensed and employed in the health care industry. College faculty and staff will not provide advice on a student’s ability to obtain licensure notwithstanding an adverse criminal background check or FCSR report, and students should not rely on any general information provided by College personnel in that regard.
A. Initial Criminal Background Checks and FCSR Reports
The College uses a qualified background check vendor to conduct its criminal background checks and FCSR reports. Students are responsible for completing the online application and doing so early enough so that results are provided to the Department of Nursing’s Clinical Compliance Coordinator no later than 5 days prior to the start of the student’s first nursing class. The vendor provides the results of student criminal background checks directly to the Clinical Compliance Coordinator for review.
Previous criminal background checks and FCSR reports the student may have received are not acceptable for purposes of this policy.
B. Additional Criminal Background Checks or FCSR Reports
Normally, criminal background checks and FCSR reports are only performed once after a student has been conditionally accepted to the Nursing Program. However, some clinical agencies may require more current results from the student prior to beginning a clinical experience at that clinical site. If an additional criminal background check or FCSR report, the student is again responsible for obtaining these in accordance with the procedures outlined above.
C. Revocation of Conditional Acceptance to Nursing Program
If a student’s criminal background check or FCSR report indicates a pending charge, criminal conviction, or other negative information, the student will be notified by mail and email that his/her conditional acceptance to the Nursing Program has been revoked, with a copy of such notification to be placed in the student’s educational file. If the student is a currently enrolled student (sophomore) he/she will be directed to his/her advisor for assistance in changing majors.
D. Sharing Information with the Clinical Agency
The College can only discuss the results of a student’s criminal background check and FCSR report with potential clinical sites if the student provides written consent to disclose such information as required by the Family Educational Rights and Privacy Act (FERPA). Therefore, students will be required to complete and sign a consent form so that the College can discuss these results with the clinical site. If a student refuses to provide this consent, the College will not be able to inform the clinical site that the student had an acceptable criminal background check and FCSR report. Likewise, the College will also not be able to share that the student had an unacceptable criminal background check or FCSR report. Without confirmation that a student has obtained a criminal background check and an FCSR report, it is very unlikely that the clinical site will allow the student to be placed there.
The consent form should be provided to the Department of Nursing’s Clinical Compliance Coordinator by electronic upload to the Document Management System utilized by the Department of Nursing.
For protection of privacy, the results of a student’s criminal background check and FCSR report will not be kept as part of the student’s normal educational file. Instead, the results will be kept separately in a secured electronic file by the Department of Nursing’s Clinical Compliance Coordinator’s office and will be retained for three (3) years following the end of the student’s enrollment at the College before being destroyed in accordance with the College’s records retention procedures.