Suitability Transfer of Background Record Checks

This page outlines additional information for EEC's suitability transfer of Background Record Checks.

The Department of Early Education and Care (EEC) runs a Background Record Check (BRC) for all individuals seeking an affiliation or employment with an EEC licensed, approved, or funded program. This process includes requesting, receiving, and evaluating information from agencies, including the Massachusetts Department of Criminal Justice Information Services (DCJIS); the Massachusetts Department of Children and Families (DCF); the Massachusetts Sex Offender Registry Board (SORB); the National Sex Offender Registry (NSOR); state and national fingerprint databases; as well as all relevant state and national criminal history, child welfare and sex offender registries, databases and repositories.

You can find the Suitability Transfer of Background Record Checks policy here. 

Frequently Asked Questions (FAQs)

  1. Are Early Intervention (EI) staff eligible for a Suitability Transfer? Early Intervention (EI) is a statewide, integrated, developmental service available to families of children between birth and three years of age and overseen by the Department of Public Health (DPH). Early Intervention staff are not required to undergo an EEC Background Record Check and instead must undergo background record checks as specified in the Early Intervention Operational Standards (CORI and SORI) and as contractually required. As a result, EI staff are not eligible for a Suitability Transfer. For more information, see EEC policy, “Background Record Checks of Early Intervention Employees and Specialty Service Providers in Early Education and Care Settings.”
  2. I am a music teacher who works for multiple Group and School Age (GSA) programs as a contractor. Do I need to apply for separate Background Record Checks for each program? No, you do not. You are an “Affiliated Person,” (see “Definitions” section for more information). This means that your Suitability Determination will transfer between the GSA programs you contract for. Each program still needs to submit a BRC Consent Form to begin the Suitability Transfer process.
  3. I am a music teacher who works for different types of programs as a contractor. Do I need to apply for separate Background Record Checks for each program? It depends. If you are an "Affiliated Person" who works for different types of programs, please check the Suitability Transfer tables on the EEC website. Reference the "Change of Program Type" tables to see if a Suitability Transfer between the two program types is possible. For example: if you are contracted by a GSA and an FCC, a Suitability transfer is possible. If you are contracted by a GSA and a Residential Program, a Suitability transfer is not possible.
  4. I run an FCC Program; my daughter lives with me and is also planning to work as an assistant in my program. How should she handle the Background Record Check process? Your daughter will need to apply for two Background Record Checks: one as an FCC Household Member and one as an FCC Assistant. EEC recommends that she apply as an FCC Assistant first, and then as an FCC Household Member. She should apply in this order because the Suitability Determination is more likely to transfer from FCC Assistant to FCC Household Member than vice-versa.
  5. What is the timeframe of the questions in the Suitability Determination Survey? Please answer these questions for the period of the last time you submitted your EEC BRC until current day. For example, when answering the question, “To your knowledge, has EEC or the BRC Program Administrator discovered that you provided false, misleading, or incomplete information?,” you would answer whether EEC or a BRC Program Administrator discovered that you provided false, misleading, or incomplete information from the last time you submitted a BRC until the day you are filling out the Suitability Determination Survey.  

Suitability Determination Survey

If the candidate has been determined suitable by EEC, they are required to answer a short survey of qualifying questions. EEC sends the candidate a link to the survey via e-mail.

Please keep in mind the following guidance as you complete the survey:

  • For all questions: The timeframe is between when the candidate last submitted an EEC BRC until current day.
  • For Question #1: This question has two parts. Answer “Yes” only if both parts are true.
  • For Question #3: If you received a suitable EEC BRC within the last 180 days and were never affiliated/employed by an EEC licensed or funded program, answer ‘No’ as this is not a break in affiliation/employment.
  • For Question #6: this includes any criminal activity, including allegations, charges, convictions, etc.
Qualifier QuestionsResponse
Have you moved outside of Massachusetts since your last EEC BRC was completed AND had a break in employment or affiliation of thirty days or longer? (Note: Question 1 has two parts. Answer “Yes” only if both parts are true.)Yes/No
To your knowledge, have you had any new criminal charges, child welfare investigations, or are you required to register or be classified as a sex offender in Massachusetts or any other state or territory?Yes/No
Have you had a break in employment with an EEC Program for more than 180 days? (Note: If you received a suitable EEC BRC within the last 180 days and were never affiliated/employed by an EEC licensed or funded program, answer ‘No’ as this is not a break in affiliation/employment.)Yes/No
To your knowledge, has EEC or the BRC Program Administrator discovered that you provided false, misleading, or incomplete information?Yes/No
To your knowledge, are you being investigated by EEC, DCF, or law enforcement?Yes/No
To your knowledge, do you have a pending criminal charge, sex offender status, or a child welfare investigation?Yes/No

Suitability Transfer for Family Child Care Programs (FCC)

Acronyms: FCC: Family Child Care program; GSA: Group and School Age program; R&P: Residential and Placement program.

Role Change within an FCC Program:

Role ARole BSuitability Transfer is Possible
FCC AssistantFCC LicenseeYes
FCC AssistantFCC Household Member / Regularly on the PremisesYes
FCC LicenseeFCC AssistantYes
FCC LicenseeFCC Household Member / Regularly on the PremisesYes
FCC Household Member / Regularly on the PremisesFCC AssistantNo
FCC Household Member / Regularly on the PremisesFCC LicenseeNo

Change of Program Type:

Request Type for Program ARequest Type for Program BSuitability Transfer is Possible
FCC ProgramAffiliated ProgramYes
FCC ProgramFunded ProgramYes
FCC ProgramGSA ProgramYes
FCC ProgramR&P ProgramNo
Affiliated ProgramFCC ProgramYes
Funded ProgramFCC ProgramYes
GSA ProgramFCC ProgramYes
R&P ProgramFCC ProgramNo

Suitability Transfer for Group and School Age Programs (GSA)

Acronyms: FCC: Family Child Care program; GSA: Group and School Age program; R&P: Residential and Placement program; EVI: Employee/Volunteer/Intern

Role Change Within a GSA Program:

Role ARole BSuitability Transfer is Possible
Affiliated Person in GSABRC Program Administrator in GSAYes
Affiliated Person in GSAEVI in GSAYes
Affiliated Person in GSALicensee in GSAYes
BRC Program Administrator in GSAAffiliated Person in GSAYes
BRC Program Administrator in GSAEVI in GSAYes
BRC Program Administrator in GSALicensee in GSAYes
EVI in GSAAffiliated Person in GSAYes
EVI in GSABRC Program Administrator in GSAYes
EVI in GSALicensee in GSAYes
Licensee in GSAAffiliated Person in GSAYes
Licensee in GSABRC Program Administrator in GSAYes
Licensee in GSAEVI in GSAYes

Change of Program Type:

Request Type for Program ARequest Type for Program BSuitability Transfer is Possible
GSA ProgramAffiliated ProgramYes
GSA ProgramFCC ProgramYes
GSA ProgramFunded ProgramYes
GSA ProgramR&P ProgramNo
Affiliated ProgramGSA ProgramYes
FCC ProgramGSA ProgramYes
Funded ProgramGSA ProgramYes
R&P ProgramGSA ProgramNo

Suitability Transfer for Funded Programs

Acronyms: FCC: Family Child Care program; GSA: Group and School Age program; R&P: Residential and Placement program; EVI: Employee/Volunteer/Intern

Change of Role Within a Funded Program:

Role ARole BSuitability Transfer is Possible
Affiliated Person in Funded ProgramBRC Program Administrator in Funded ProgramYes
Affiliated Person in Funded ProgramDesignated Administrator in Funded ProgramYes
Affiliated Person in Funded ProgramEVI in Funded ProgramYes
BRC Program Administrator in Funded ProgramAffiliated Person in Funded ProgramYes
BRC Program Administrator in Funded ProgramDesignated Administrator in Funded ProgramYes
BRC Program Administrator in Funded ProgramEVI in Funded ProgramYes
Designated Administrator in Funded ProgramAffiliated Person in Funded ProgramYes
Designated Administrator in Funded ProgramBRC Program Administrator in Funded ProgramYes
Designated Administrator in Funded ProgramEVI in Funded ProgramYes
EVI in Funded ProgramAffiliated Person in Funded ProgramYes
EVI in Funded ProgramBRC Program Administrator in Funded ProgramYes
EVI in Funded ProgramDesignated Administrator in Funded ProgramYes

Change of Program Type:

Request Type for Program ARequest Type for Program BSuitability Transfer is Possible
Funded ProgramAffiliated ProgramYes
Funded ProgramFCC ProgramYes
Funded ProgramGSA ProgramYes
Funded ProgramR&P ProgramNo
Affiliated ProgramFunded ProgramYes
FCC ProgramFunded ProgramYes
GSA ProgramFunded ProgramYes
R&P ProgramFunded ProgramNo

Suitability Transfer for Residential Programs

Acronyms: FCC: Family Child Care program; GSA: Group and School Age program; R&P: Residential and Placement program; EVI: Employee/Volunteer/Intern

Change of Role Within a Residential Program:

Role ARole BSuitability Transfer is Possible
Affiliated Person in ResidentialAffiliated Person in PlacementYes
Affiliated Person in ResidentialBRC Program Administrator in PlacementYes
Affiliated Person in ResidentialBRC Program Administrator in ResidentialYes
Affiliated Person in ResidentialEVI in PlacementYes
Affiliated Person in ResidentialEVI in ResidentialYes
Affiliated Person in ResidentialLicensee in PlacementYes
Affiliated Person in ResidentialLicensee in ResidentialYes
BRC Program Administrator in ResidentialAffiliated Person in PlacementYes
BRC Program Administrator in ResidentialAffiliated Person in ResidentialYes
BRC Program Administrator in ResidentialBRC Program Administrator in PlacementYes
BRC Program Administrator in ResidentialEVI in PlacementYes
BRC Program Administrator in ResidentialEVI in ResidentialYes
BRC Program Administrator in ResidentialLicensee in PlacementYes
BRC Program Administrator in ResidentialLicensee in ResidentialYes
EVI in ResidentialAffiliated Person in PlacementYes
EVI in ResidentialAffiliated Person in ResidentialYes
EVI in ResidentialBRC Program Administrator in PlacementYes
EVI in ResidentialBRC Program Administrator in ResidentialYes
EVI in ResidentialEVI in PlacementYes
EVI in ResidentialLicensee in PlacementYes
EVI in ResidentialLicensee in ResidentialYes
Licensee in ResidentialAffiliated Person in PlacementYes
Licensee in ResidentialAffiliated Person in ResidentialYes
Licensee in ResidentialBRC Program Administrator in PlacementYes
Licensee in ResidentialBRC Program Administrator in ResidentialYes
Licensee in ResidentialEVI in PlacementYes
Licensee in ResidentialEVI in ResidentialYes
Licensee in ResidentialLicensee in PlacementYes

Change in Program Type:

Request Type for Program ARequest Type for Program BSuitability Transfer is Possible
ResidentialAffiliated ProgramNo
ResidentialFCC ProgramNo
ResidentialFunded ProgramNo
ResidentialGSA ProgramNo
Affiliated ProgramResidentialNo
FCC ProgramResidentialNo
Funded ProgramResidentialNo
GSA ProgramResidentialNo


 

Suitability Transfer for Placement Programs

Acronyms: FCC: Family Child Care program; GSA: Group and School Age program; R&P: Residential and Placement program; EVI: Employee/Volunteer/Intern

Change of Role Within a Placement Program:

Role ARole BSuitability Transfer is Possible
Affiliated Person in PlacementBRC Program Administrator in ResidentialYes
Affiliated Person in PlacementEVI in PlacementYes
Affiliated Person in PlacementLicensee in PlacementYes
BRC Program Administrator in PlacementAffiliated Person in PlacementYes
BRC Program Administrator in PlacementEVI in PlacementYes
BRC Program Administrator in PlacementLicensee in PlacementYes
EVI in PlacementAffiliated Person in PlacementYes
EVI in PlacementBRC Program Administrator in PlacementYes
EVI in PlacementLicensee in PlacementYes
Licensee in PlacementAffiliated Person in PlacementYes
Licensee in PlacementBRC Program Administrator in PlacementYes
Licensee in PlacementEVI in PlacementYes
Affiliated Person in PlacementAffiliated Person in ResidentialNo
Affiliated Person in PlacementBRC Program Administrator in ResidentialNo
Affiliated Person in PlacementEVI in ResidentialNo
Affiliated Person in PlacementLicensee in ResidentialNo
BRC Program Administrator in PlacementAffiliated Person in ResidentialNo
BRC Program Administrator in PlacementBRC Program Administrator in ResidentialNo
BRC Program Administrator in PlacementEVI in ResidentialNo
BRC Program Administrator in PlacementLicensee in ResidentialNo
EVI in PlacementAffiliated Person in ResidentialNo
EVI in PlacementBRC Program Administrator in ResidentialNo
EVI in PlacementEVI in ResidentialNo
EVI in PlacementLicensee in ResidentialNo
Licensee in PlacementAffiliated Person in ResidentialNo
Licensee in PlacementBRC Program Administrator in ResidentialNo
Licensee in PlacementEVI in ResidentialNo
Licensee in PlacementLicensee in ResidentialNo

Change in Program Type:

Request Type for Program ARequest Type for Program BSuitability Transfer is Possible
PlacementAffiliated ProgramNo
PlacementFCC ProgramNo
PlacementFunded ProgramNo
PlacementGSA ProgramNo
Affiliated ProgramPlacementNo
FCC ProgramPlacementNo
Funded ProgramPlacementNo
GSA ProgramPlacementNo

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