Questions on Background Record Check (BRC) Requirements: Applicability

Questions in this section are about who needs to have an EEC Background Record Check.

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On October 1, 2018, must all child care candidates in EEC-licensed programs complete a BRC?

On October 1, 2018 must all child care candidates in EEC-licensed programs (including janitors and cooks) -- regardless of their potential for unsupervised access to children -- complete a Background Record Check (BRC)?

For group and school age child care and funded programs, EEC is implementing a policy that requires all staff to be run.  For residential programs and placement agencies, only those individuals present in an EEC-licensed program with the potential for unsupervised access to children (including household members and persons regularly on the premises in family child care homes) must complete a Background Record Check (BRC). Licensed programs must ensure that all individuals in their program who have the potential for unsupervised access to children have their Background Record Check renewed on time, and that any prospective candidates who have unsupervised access to children, and any new household members in family child care homes and individuals regularly on the premises of child care homes, complete a Background Record Check.  For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: EEC Background Record Check Process by Program Type (EEC BRC POLICY NUMBER: 19-004) and the Interns and Volunteer (EEC BRC POLICY NUMBER: 19-008) EEC Background Record Check Policy: Early Intervention and Specialty Service Providers EEC BRC POLICY NUMBER: 19-001; EEC POLICY STATEMENT: Clarifying the “All Candidates” Requirement for Background Record Checks for Group and School Age Child Care, EEC BRC POLICY NUMBER: 19-014; EEC POLICY STATEMENT: Clarifying the “All Candidates” Requirement for Background Record Checks for CCDF-Funded Child Care Programs EEC BRC POLICY NUMBER: 19-015

My program is located within another, larger, organization. Which “all staff” must have a BRC?

My program is located within another, larger, organization. In this case, who does the “all staff” requirement apply to? Is it everyone in my immediate program, or does it include everyone in both the child care program and everyone in the parent company?

The all staff requirement applies to all staff of the child care program. It does not include related programs that are not a part of the child care facility. For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: EEC POLICY STATEMENT: Clarifying the “All Candidates” Requirement for Background Record Checks for Group and School Age Child Care, EEC BRC POLICY NUMBER: 19-014; EEC POLICY STATEMENT: Clarifying the “All Candidates” Requirement for Background Record Checks for CCDF-Funded Child Care Programs EEC BRC POLICY NUMBER: 19-015

Do Volunteers or Third-Party Individuals (such as ABA therapists, etc.) need to complete a BRC?

Do Volunteers or Third-Party Individuals (such as ABA therapists, etc.) need to complete a Background Record Check (BRC)?

Any individual assisting in an unsupervised capacity and third parties assisting in an unsupervised capacity must complete an EEC Background Record Check. If the volunteer or third-party individual does not have the potential for unsupervised access to the children in the program they would not need to complete a Background Record Check.  For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: BRC Process by Program Type (EEC BRC POLICY NUMBER: 19-004), Interns and Volunteers (EEC BRC POLICY NUMBER: 19-008), and the Early Intervention Policy EEC BRC POLICY NUMBER: 19-001 

Who is considered a 3rd party?

Who is considered a 3rd party?

This is defined in EEC regulations as an affiliated person, which is defined as, “Regular association with an EEC licensed, approved or funded Program through employment, contract or an informal agreement with the Program or parents for the purpose of providing services on behalf of the Program or a child in attendance.” See 606 CMR 14.04.

For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: EEC Background Record Check Process by Program Type (EEC BRC POLICY NUMBER: 19-004)

Must a Program Administrator run a 3rd party's BRC, or will their organization run it?

As a BRC Program Administrator, am I responsible for running a 3rd party’s BRC, or will their organization run this for them?

A BRC Program Administrator is responsible for ensuring that third parties who have unsupervised access to children complete an EEC BRC. For GSA and funded programs, third parties may be run through the EEC BRC Navigator Program Portal as an affiliated individual. Alternatively, they may be run by creating an “agency” by having the affiliated/third party call the BRC Unit to set up an account. The “agency” function should be used for agencies that contract with many child care programs or have a large number of staff. For residential programs and placement agencies, the candidate can also be run as a staff if the “agency” function does not work for the organization. For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: EEC Background Record Check Process by Program Type (EEC BRC POLICY NUMBER: 19-004), and BRC Program Administrator Role in BRC Navigator (EEC BRC POLICY NUMBER: 19-007)

If another organization has run the BRC for the 3rd party, how do I know it is still valid?

If another organization has run the BRC for the 3rd party, how do I know it is still valid?

The program needs to be affiliated with an agency to be able to view the suitability letters of the individual’s submitted by the agencies. Licensee/Reviewers of the programs will have the option available on the homepage of BRC Manager to affiliate with an agency.New candidates being submitted in the BRC Navigator should be run in the role of “affiliated individual”.  BRC Information is Available to Programs in BRC Navigator (EEC BRC POLICY NUMBER: 19-017) and Transfer of Suitability and Frequency of BRCs (EEC BRC POLICY NUMBER: 19-006)

Would an occasional volunteer be required to get a BRC? What about occasional chaperones?

Would an occasional volunteer be required to get a BRC? What about occasional chaperones?

Any regular volunteer or chaperone (those who are regularly present) would need to have a BRC run. Occasional volunteers and chaperones (those only infrequently present) do not need to have a BRC run unless they have unsupervised access to children.

Any volunteer or chaperone with unsupervised access to children must have an EEC BRC run. For more information, please refer to the Background Record Check Policies on EEC’s website, specifically: Interns and Volunteers (EEC BRC UNIT POLICY NUMBER: 19-008)

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