Employment Background Check Policy
Washington University performs background checks and screenings to promote the safety of its community and operations. Generally, background checks and screenings will be conducted for new hires to any faculty/academic, staff, postdoc, clinical fellow position, regardless of FTE, standard hours, or primary work location. Screenings may also be required for internal transfers, reclassifications, promotions, or addition of duties to positions that may necessitate additional screening.
Generally, backgrounds screenings are conducted following the acceptance of a formal offer of employment or appointment and are distinct from pre- or post-offer reference checks or reviews of a candidate’s licensure or other qualifications.
Background screenings will not be required for former employees who return to the University within 90 days, unless (1) the position to which they are returning requires an additional screening not previously completed, and (2) they have not undergone a university background screening within 90 days.
Any misrepresentation during the application or interview process is grounds for denial of employment, withdrawal of offer or termination.
Prior to Job Offer: The following background screenings may be conducted at any time prior to the job offer.
- Job Skills Assessment
- Some positions may require that the applicant demonstrate competency in certain skills. Testing and assessment must be performed on a consistent and nondiscriminatory basis. If one applicant is tested/assessed, then all applicants under serious consideration for the job typically should be tested/assessed. Human Resources should be consulted prior to any proficiency testing of applicants to ensure compliance with university policy.
- Reference Checks
- Careful and objective reference checking provides important information critical in the evaluation of a potential employee whose prior education, experience and/or performance constitutes significant qualification for employment/placement. Generally, no final offer should be extended to an employee or transfer candidate until previous employment references have been contacted and suitability of the individual for the position is confirmed.
Generally, this can be done most effectively by the hiring manager or department head, since they have the greatest familiarity with the duties and requirements of the position. The Office of Human Resources can provide guidance in checking references and may assist if requested.
Following a Conditional Job Offer: The following screenings may be required following a conditional offer of employment, placement, transfer, job reclassification, promotion or addition of certain job duties.
New Hires:
All new faculty, staff, postdoctoral and clinical fellow workers are subject to the following basic background check and screening requirements:
- Social Security Number Validation/Trace – validate the social security number, date of birth and former addresses.
- Criminal Record Check (Federal and Statewide/County)
- National Sex Offender Registry
Other screenings may be required if applicable to the position:
- Professional License, Registration or Certification Verification
- Education Verification – based on degrees/education requirement noted in the job profile/description. confirms the applicant’s claimed educational institution, including the years attended and the degree/diploma received.
- Employment Verification – prior work history verification beyond what was confirmed via reference checks. Normally includes employment dates, job title, etc.
- Drug screenings are required for those newly hired and may be required for transferring who have not completed such screening at any point in their employment. Individuals selected into positions that have direct patient care or patient facing responsibilities are subject to this requirement. Other job profiles may be subject to drug screen as deemed necessary based on depts or school requirements.
- Federal and/or State EDL/Disqualifications lists
- Fitness for Duty Assessment
- Credit History Check
- Motor Vehicle
- DOT certification
- Others as required
Generally, transfer employees are only subject to additional screenings that may be new requirements based on the newly acquired role.
Notice to Applicant of Conditional Offer:
While the job postings on the Office of Human Resources website will note general background check and screening requirements, Managers are responsible for notifying candidates of specific screening requirements for the position at the time of interview and offer.
Candidates should be informed that any offer of employment or transfer is contingent upon a successful background check and screening. Prior to conducting the background check or screening, a signed or e-signed consent to conduct the check must be obtained from the candidate. Refusal to authorize a background screening will disqualify the candidate. Background checks and screenings may be conducted by the University and/or an external third-party vendor.
Evaluation of Background Screening Results. Generally, employment in the position may not begin until the University has reviewed the results of the background check and screening and made a final determination regarding the contingent offer.
Human Resources will review the results of the background screening. If the results raise questions concerning the candidate’s suitability for the position, Human Resources will inform the hiring unit of the concerns and consult with, as applicable, the hiring manager, Vice Chancellor, Executive Vice Chancellor, Dean, and/or Provost.
A prior criminal record will NOT automatically disqualify the candidate. In determining whether a criminal record will result in revocation of the offer, the University conducts an individualized assessment that includes the following considerations: the nature, number and gravity of the offense(s); the length of time that has elapsed since the offense; and whether and the degree to which the offense is related to the duties and responsibilities of the position.
If adverse action is probable based on the results of a background screening, the candidate will receive a copy of the background screening report, a pre-adverse action notice, and a document summarizing the candidate’s rights under the Fair Credit Reporting Act (FCRA). Candidates may provide responsive information within five business days.
The final determination regarding the contingent offer will be made jointly by Human Resources and the applicable administrators referenced above. If the offer is rescinded, the candidate will receive an adverse action notice and a document summarizing the candidate’s rights under the FCRA.
Confidentiality. Information obtained through background screenings is confidential and will only be shared with individuals with a legitimate business need to know. Records of background screenings will be maintained by Human Resources.
Use of Information. Information discovered through the background screening process will be used solely for the purpose of evaluating a candidate’s suitability for employment and will not be used to discriminate against a candidate on the basis of race, color, religion/creed, sex/gender, age, sexual orientation, gender identity/expression, national origin, genetic information, marital/familial status, disability, military, veteran status, or any other protected status.
Reporting Obligation. All employees have an ongoing responsibility during their employment to inform Human Resources of any criminal conviction (including guilty or no contest pleas).
Other required background check and screenings:
- Supervision of Minors. For information about background screenings of employees whose job duties include supervision of minors, please see the University’s Youth Protection Policy.
- Controlled Substance Policy. For information about background screenings of employees whose job duties include access to controlled substances, please see https://research.wustl.edu/topics/controlled-substances/.
- Controlled Unclassified Information (CUI) in Sponsored Research. For information about background screenings of individuals who work on projects that involves CUI, please see https://informationsecurity.wustl.edu/cmmc-at-wustl-and-security-of-controlled-unclassified-information-cui-in-sponsored-research/.
Policy Exceptions. Exceptions to this policy may be made at the discretion of the University through the Vice Chancellor of Human Resources & Institutional Equity or designee.