HR-Internal-06 Background Reviews Administrative Standards

Policy Number: T10-088 
Functional Area: HUMAN RESOURCES
Brief Description: Revised Administrative Standards
Effective:April 16, 2019
Responsible Office: Senior Vice President for Administration and Finance & Treasurer
Last Reviewed/Updated: April 23, 2025

Reason for Policy: The purpose of this Policy is to establish the University’s commitment to providing a safe and secure environment that is supported by qualified employees for all of its students, faculty, staff, and residents to carry out the University's teaching, research, and public service missions.

I. Policy Statement.

The University of Massachusetts is committed to providing a safe and secure environment that is supported by qualified employees for all of its students, faculty, staff, and residents to carry out the University's teaching, research, and public service missions. As a condition of employment, the University will conduct appropriate background reviews for all new hires. This policy will be implemented in a manner consistent with the rights of privacy, equal opportunity, and academic freedom afforded to those who serve the University.

Administrative Standards for the University of Massachusetts Policy on Employee Background Checks 

(Doc. T10-088)

The following administrative standards are issued pursuant to the University of Massachusetts Policy on Employee Background Reviews (Doc. T10-088). Subject to these administrative standards, the Chancellors shall develop and promulgate detailed campus procedures for the conduct of employee background reviews. The below administrative standards are effective as of April, 16, 2019. They replace the previous standards which went into effect on September 9, 2016.

1. Types of Background Reviews

   1. New Hires

      As a condition of employment, every new hire at the University shall be subject to a
      Standard Background Review that includes the following:

      • Social Security Trace;
      • Criminal history search1footnote of the past seven years of residence including;
        • Statewide criminal record search (if available and comprehensive)2footnote;
        • If a comprehensive statewide criminal record repository is not available, county criminal record search;
        • International Search if a foreign address is uncovered within the last seven years;
        • Federal criminal record search;
        • National criminal record locator database.
      • State Sex Offender registry search;
      • National Sex Offender registry search;
      • Employment Verification of the last three employers; and
      • Education Verification of the highest level completed.

      New Hires include existing employees who transfer from one University campus to another.

      As required by position qualifications, a professional or trade license verification will also be conducted.

      In addition, the University may require as a condition of employment for candidate finalists for appropriate positions, as identified by each campus and/or as required by law or clinical placement requirements, such other background review search types including but not limited to financial history, credit, motor vehicle records, reference reviews, drug testing, debarred lists and/or certification verification.

   2. Rehires

      Individuals rehired by the University with a break in service of 364 days or less shall not be subject to a background review unless hired into a Protection of Minors covered position. (See below for Protection of Minors Background Reviews.)

      Individuals rehired by the University with a break in service between one (1) and two (2) years shall have a Rehire Background Review conducted that includes the following:

      • Social Security Trace;
      • Criminal history search of the past seven years of residence including;
        • Statewide criminal record search (if available and comprehensive);
        • If a comprehensive statewide criminal record repository is not available, county criminal record search;
        • International Search if a foreign address is uncovered within the last seven years;
        • Federal criminal record search;
        • National criminal record locator database;
      • State Sex Offender registry search;
      • National Sex Offender registry search; and
      • Other searches as may be applicable based on position.

      Individuals rehired by the University with a break in service of more than two (2) years shall have a Standard Background Review conducted as described above. 

      Note that layoff and recalls are subject to the Rehire Background Review and Standard Background Review as described above.

   3. Protection of Minors

      Positions including unsupervised contact with minors, who may or may not be enrolled as students of the University, such as cooperative programs, summer youth camps and athletes must have an iCORI conducted as part of the Standard Background Review. (See MGL Section 172H.)

      “Unsupervised” is defined as in the presence minors as described above in a confined room or work space without the presence of another adult; or being the presence outside the view of another adult within thirty (30) feet; Examples of these positions include but are not limited to Medical personnel, camp counselors, coaches, child and eldercare personnel. 

      Protection of Minors positions will have an Annual Protection of Minors Background Review. See CMR 430.090(C). Annual Protection of Minors Background Review includes at a minimum:

      • iCORI
      • Federal criminal record search;
      • State Sex Offender registry search;
      • National Sex Offender registry search; and
      • National criminal record locator database.

      Campuses may, at their discretion or as required by law, conduct additional annual search types in addition to above.

   4. Regulated Positions

      Positions regulated by federal, state, or local laws or regulations, including but not limited to positions with direct access to biological/biochemical agents and/or radiation labs and positions regulated by the Department of Transportation will have background reviews conducted in accordance with applicable laws and regulations. Periodic reinvestigations may also be conducted on regulated positions.

2. The successful finalist candidate for each position shall be required to complete a pre-employment form on which they attest that they understand that their employment is subject to the background reviews described above. In addition, each such candidate shall be required to indicate under penalties of perjury whether they have been convicted of a felony within the past seven years.
3. Campuses may, at their discretion, include a reference to the University's Policy on Employee Background Reviews in position advertising and descriptions.
4. Each campus shall identify the central administrative office(s) that will be authorized to request,
   review, and maintain security for background reviews.
5. The University utilizes a third party Consumer Reporting Agency to conduct background reviews (otherwise referred to as “consumer reports”) and is therefore subject to the obligations under the Fair Credit Reporting Act (FCRA) for background reviews.
6. Users of Consumer Reports are required to read and understand Exhibit A – Notice to Users of Consumer Reports: Your Obligations of Users Under the FCRA.
7. Campuses shall develop procedures under which candidates for employment may challenge and seek to correct inaccurate information contained in their consumer report.
8. Campuses, at their discretion, may utilize the third-party vendor administrative service for pre-adverse and adverse action notices. Refer to Exhibit B – FCRA Administration Program.
9. Campuses accessing Massachusetts Department of Criminal Justice Information Services (DCJIS) for Criminal Offender Record Information (iCORI), in Massachusetts directly or through the third-party vendor are subject to the regulations of the Massachusetts Department of Criminal Justice Information Services. Users of iCORI are subject to the DCJIS CORI Policy outlined in Exhibit C – CORI Policy.
10. Campuses shall develop procedures under which candidates for employment may challenge and seek to correct iCORI information contained in background reviews that they believe to be inaccurate.
11. Campuses, at their discretion, may utilize the third-party vendor’s administrative service for pre-adverse and adverse action notices.
12. All records of background reviews shall be kept separate from other personnel files, and access to the records shall be limited to certified University personnel responsible for the conduct and processing of such reviews.
13. Unless as otherwise required by federal or state law, determinations of suitability for employment shall be made consistent and in compliance with University policies and standards and applicable laws and regulations. Refer to Section VII in CORI Policy.
14. In addition, unless as otherwise required by federal or state law, prior to any adverse action, the University will conduct an individualized assessment of the iCORI results. Other relevant individualized evidence includes:
    • The facts or circumstances surrounding the offense or conduct;
    • The number of offenses for which the individual was convicted;
    • Evidence that the individual performed the same type of work, post-conviction, with the same or a different employer, with no known incidents of criminal conduct;
    • The length and consistency of employment history before and after the offense or conduct;
    • Rehabilitation efforts, e.g., education/training;
    • Employment or character references and any other information regarding fitness for the particular position;
    • Whether the individual is bonded under a federal, state, or local bonding program; and
    • When the offense occurred and whether the offender was a juvenile.
15. Whenever the University uses a consumer reporting agency (CRA) to conduct background reviews in accordance with these standards, the CRA will furnish an annual Service Organization Controls 2 Type II (SOC 2) report.
16. All contracts with executive search firms must include a provision requiring the search firm to conduct and document background checks that meet university and campus requirements. The completion of the same, along with a review of the results by the appropriate campus Human Resources officer, must be verified and documented as part of the selected candidate’s hiring process.
17. The above standards shall apply to all positions. A campus may establish procedures more stringent than those called for above and may, at its discretion or as required by law, require background reviews for other positions, including contractors, consultants, vendors or otherwise.
18. The President of the University, or designee, in consultation with General Counsel, shall have the authority to interpret and amend these standards.

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  Criminal searches include searching all names and addresses provided by the applicant as well as surfaced through the Social Security Trace.

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  By July 1, 2018, all campuses and the system office will be conducting iCORIs on all hires and rehires, as part of the Criminal History Search.