Volunteers and Caregivers: Background Check Policies

By Michael Klazema on 9/1/2020

Which role should background checks play for aged care providers? Michigan recently took a big step in standardizing certain parts of the background check policies for aged care providers throughout the state. The move provides a clue to how nursing homes and other senior-serving businesses or organizations might build effective background check policies for their staff, volunteers, contractors, and subcontractors.

The new Michigan rules don’t apply to all senior-geared entities in the state. The requirements were put in place by the Michigan Commission on Services to the Aging specifically for the Aging and Adult Services Agency (AASA).

The AASA is an agency responsible for managing “approximately $110 million in non-Medicaid federal and state funding for home and community-based programs to serve Michigan’s older and vulnerable adults through the aging network.” The agency funds 16 smaller-area aging agencies throughout the state, regional nonprofits formed by federal and state legislation that exist to meet the needs of seniors in local communities. There are also sub-agencies affiliated with the AASA—in total, the group is more than 1,000 organizations strong.

All AASA agencies and sub-agencies will be impacted by the commission’s new criminal background check rules. The requirements do not change anything about the background checks that AASA affiliates must conduct. All agencies and sub-agencies already require staff, volunteer, and contractor background checks for anyone working closely with older adults, including criminal history and sex offender registry checks. The new policy seeks to standardize how background checks are handled throughout the AASA network.

Previously, agencies had different policies about which types of criminal history demanded disqualification from employee or volunteer consideration, as well as varying rules about repeat background checks. These matters will be standard in the future.

New requirements include:

  • All programs will need to update background checks for all staff, volunteers, and contractors every three years.
  • All existing employees will start over with background checks when the new requirements go into effect. Employees or volunteers hired “prior to the effective date of the policy” must be re-screened within 90 days; after that, background checks will be required “no later than 30 days after every third anniversary from the date of their last background check.”
  • All programs must follow the same set of exclusions when reviewing background checks and deciding whether to hire someone or bring them aboard as a volunteer.

The exclusions bar employees or volunteers from any position that allows them “to work directly with clients or have access to a client’s personal property or confidential client information” if their background checks show certain types of criminal history. There are both mandatory exclusions, which apply no longer how much time has passed since the conviction; and lighter restrictions, which only apply if the conviction took place within the past ten years.

Mandatory exclusions include any crimes against a vulnerable adult, violent offenses (murder, manslaughter, assault, domestic violence), financial crimes (fraud, forgery, embezzlement), sex crimes (rape, sexual abuse, prostitution), crimes involving any form of abuse or neglect, felonies “involving the use of a firearm or dangerous weapon,” and crimes that involve any form of cruelty or torture.

The lighter exclusions include “crimes involving state, federal, or local government assistance programs,” theft-related crimes (burglary, robbery, extortion, false representation), and convictions involving drugs (possession, manufacturing, delivery).

At, we regularly help organizations to develop employeecontractor, and volunteer background checks. If your aged care facility needs a new background check protocol for vetting personnel, we can offer resources and trusted services to assist. Contact us today to learn more.

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