Doctor of Medicine Program Criminal Background Check, Toxicology Screening and Procedures

PART I. CRIMINAL BACKGROUND CHECK, TOXICOLOGY SCREENING AND DISCLOSURE POLICY AND PROCEDURES

Policy

The Keck School of Medicine of the University of Southern California (“Keck”) requires applicants who have been conditionally accepted to the Doctor of Medicine Program to participate in and provide the results of a national and, where applicable, international criminal background check. Keck also requires that accepted students undergo Live Scan fingerprinting as part of the onboarding requirements for the Los Angeles County+USC Medical Center.

No information obtained by Keck from a criminal background check will automatically disqualify a conditionally accepted applicant from obtaining full admission. However, omission of required information or submitting false or misleading information by the applicant in the AMCAS and/or in any communication with Keck or the agencies conducting the criminal background check will result in rescission of conditional acceptance.

Certiphi Screening (“Certiphi”) Criminal Background Check (“CBC”) Background

The Association of American Medical Colleges (AAMC) recommends that all U.S. medical schools obtain a national and/or international background check on applicants upon their initial, conditional acceptance to medical school. The AAMC has initiated an American Medical College Application Services (“AMCAS”)-facilitated national criminal background check service through Certiphi Screening. The purposes of conducting criminal background checks are multiple:

To ascertain the ability of accepted applicants to eventually become licensed physicians in the future.
To ensure the public’s continuing trust in the medical profession.
To protect the safety and well-being of patients.
To identify accepted applicants who have criminal histories that may result in their ineligibility to train at primary or affiliated clinical training sites.
To comply with various regulatory or accrediting agencies that require, or recommend, such checks, as well as any applicable state or federal laws.
To make applicants with a criminal history aware that their record may impact their ability to obtain professional licensure.

CBC Process through Certiphi Screening:

Applicants are required to provide consent to Certiphi screening to conduct the CBC.
After January 1 of the application year, conditionally accepted applicants will receive an email from Certiphi Screening at the primary email address provided with their AMCAS application requesting the applicant’s consent to perform the background check.
After the applicant provides consent, Certiphi Screening, will obtain a national and, where applicable, international criminal background check. Certiphi Screening will email the applicant when the background check is completed and request that it be reviewed prior to distribution to Keck.
1. The applicant will have ten (10) calendar days from when they receive the email to review the report before it is sent to the Keck School of Medicine.
2. If the ten (10) calendar days elapse and the applicant does not review the report, it will be sent to the school.
3. The applicant will be given the opportunity to contest the contents of the report within the specified ten (10) calendar days.
If, for any reason, the applicant fails to provide consent for the background check or the results of the background check are not provided to Keck, Keck will rescind the applicant’s conditional acceptance.
If no adverse information is found on the applicant’s criminal background check, the Office of Admissions may issue a full acceptance.
In the event adverse information is reported, Keck will review the information using the process outlined in the Handling of Adverse CBC and Live Scan Reports and may, but is not required to, contact the applicant prior to a decision being rendered.

Live Scan Fingerprinting at LAC+USC Medical Center (LAC+USC)

Live Scan is the digitally scanned fingerprinting process LAC+USC uses to obtain fingerprints. Live Scan allows digitally scanned fingerprints and related information to be submitted electronically to the Department of Justice (DOJ) and the Federal Bureau of Investigations (FBI). The LAC+USC Human Resources Office manages the Live Scan process. All students matriculating at Keck are required to undergo a Live Scan fingerprinting background check.

Live Scan fingerprinting Process:

Students will be required to undergo Live Scan fingerprinting as part of the first-year orientation program to clear them for participation in clinical education at LAC+USC. Students must authorize the release of the results of the Live Scan to LAC+USC.
If the applicant fails to provide consent for the Live Scan for any reason, Keck will rescind the applicant’s acceptance.
If no adverse information is found on the applicant’s Live Scan, the Office of Admissions may issue a full acceptance.
LAC+USC Criminal Background Unit (CBU) manages adverse results of a Live Scan report directly with the applicant. If an adverse action is found on an applicant’s Live Scan, the CBU will send a letter to the applicant informing them that a conviction hit was found from the Live Scan.
The applicant will have an opportunity to respond in writing regarding the conviction hit.
The CBU will review all information and make the final determination on whether or not the student would be allowed to participate in clinical education at the LAC+USC.
If the CBU denies clinical education privileges to an applicant, Keck will review the information as provided in the Handling of Adverse CBC and Live Scan Reports and may, but is not required to, contact the applicant prior to a final admissions decision being rendered.

Handling of Adverse CBC and Live Scan Reports

The Office of Admissions will review the CBC report and the applicant’s explanation (if requested) before an offer of admission is rescinded. The Office of Admissions is not required to request additional information from the applicant.

Review process:

In making a final decision on an applicant’s rescission of admission, factors that the Office of Admissions may consider include but are not limited to:

The nature and seriousness of the offense
The circumstances under which the offense occurred
The relationship between the duties to be performed as part of the School of Medicine’s curriculum, including clinical components, and the offense committed
The age of the person when the offense was committed
Whether the offense was an isolated or repeated incident
The length of time that has passed since the offense
Past employment and volunteer experiences
Evidence of successful rehabilitation
Forthrightness of the information about the incident in the opportunities for self-disclosure

The Office of Admissions will review each case, focusing on the applicant’s suitability for the profession of medicine, threats to individual patients, and risks to the School of Medicine and the community.

The Office of Admissions may, but is not required to, request that the applicant provide additional information including a written description and explanation of the information contained in the CBC report or, and supporting documentation including, but not limited to, police reports. The applicant will have ten (10) working days to provide information from the date the request is sent by email to the applicant. The Office of Admissions may also independently seek additional information about the incident that is the subject of the report.

Final decisions about the rescission of an applicant’s conditional acceptance will be made by the Associate Dean of Admissions. The Associate Dean of Admissions decision is not appealable.

Deferred Applicants

Deferred applicants will be required to undergo a second Certiphi CBC. The first will be conducted after the initial, conditional offer of admission. This check MUST be successfully completed, and the admission offer finalized prior to the Office of Admissions considering a request for deferment. If the deferment request is granted, the applicant will be required to undergo a second background check as part of the application cycle for the cohort in which the applicant intends to matriculate. If the second background check identifies a new issue, appropriate action will be taken which may include revocation of the offer of admission.

Live Scan fingerprinting will be conducted during the first-year orientation of the year to which the applicant matriculates.

Ongoing Duty to Report

Applicants and/or enrolled students are required report any events which may impact their background check that occur after a CBC report has been issued. These reports must be made in writing to the Associate Dean for Student Affairs as soon as possible, but in no case more than 72 hours after the event in question. Failure to comply may result in sanctions, up to and including dismissal from the program.

PART II. ADDITIONAL BACKGROUND CHECKS, TOXICOLOGY SCREENING AND DISCLOSURES POLICY – CLINICAL FACILITY PLACEMENTS

Policy Statement:

In addition to the criminal background checks and/or toxicology screening required as part of the admissions process as set forth in Part I of this Policy and Procedure, students at Keck may be required at any time to obtain and pass additional background checks, toxicology screening and/or finger printing checks (“Screenings”) by clinical affiliates of Keck in order to participate in a variety of clinical facility placements. All toxicology testing will be performed by a licensed independent medical lab. Additional vendors or screenings may be identified or required by clinical affiliates. Failure to comply may result in sanctions, up to and including dismissal from the program.

Admitted and/or enrolled students are required to report any events which may impact the outcome of their background check that occur after a CBC report has been issued. These reports must be made in writing to the Associate Dean for Student Affairs as soon as possible, but in no case more than 72 hours after the event in question. Criminal convictions or other adverse events may prevent placement at a clinical training site. Failure to report any change in status may result in referral to the Student Performance Committee and will be considered unprofessional conduct, which may result in sanctions up to and including dismissal.

Policy Process:

Additional criminal or other background checks and/or Screenings may be required at any time by clinical affiliates of Keck. Failure to comply may result in sanctions, up to and including dismissal from the program.
The cost of obtaining these additional screenings will be covered by Keck if the student is assigned to complete a required clerkship at a clinical affiliate that requires additional screening. Students are responsible for the cost of these additional screenings for elective courses if they are required by the host institution.
Students must provide directly, or authorize the release of, reports of the results of required additional criminal or other background checks and/or Screenings to Keck and, when appropriate, its clinical affiliates.
If information in the report disqualifies the student from participating at the facility (as determined by the designated individual[s] at the clinical affiliate), or is otherwise unacceptable to the clinical affiliate, the student will be responsible for obtaining the necessary documents to correct/explain the information, if provided with the opportunity to do so.
If the issue is not resolved to the satisfaction of the clinical affiliate, in its sole discretion, the student may not be able to participate in a clinical program and may be unable to complete the requirements for the MD degree. It is the responsibility of the clinical affiliate to determine if a student meets the requirements to rotate at its facility.
Reports of results of required additional criminal or other background checks and/or toxicology screenings that contain information unacceptable to Keck and/or the clinical facility may result in sanctions, including but not limited to: the inability to rotate through various affiliate sites, delayed graduation, suspension and/or dismissal at the discretion of the designated Student Affairs Dean in consultation with the Student Performance Committee. A student with a positive toxicology screen for non prescribed substances, or an adverse criminal background check will be immediately removed from educational activities until the Associate Dean of Student Affairs and/or Student Performance Committee have developed a management plan. Students who have an adverse LiveScan will be managed according to the policies of the Los Angeles County + USC Medical Center.

The following are the minimum areas of inquiry typically covered in the background check requested by USC’s clinical partners, although some partners may require a more comprehensive background check:

Seven year criminal court history
Address verification
Sex offender database search
Two names verification: current legal and one other name (AKA)
Three county check of records
Search of the Department of Health and Human Services Office of the Inspector General database of excluded persons.
Social security number verification.

Screenings:

All toxicology testing will be performed by a licensed independent medical lab.

Fingerprinting is done through LiveScan by the Los Angeles County Department of Human Resources.

Additional vendors or screenings may be identified or required by clinical affiliates.

Record Retention

The Office of Medical Education at the Keck School of Medicine of USC abides by the Record Management Policy established by the University of Southern California. https://policy.usc.edu/record-management/. As an official repository for medical student records, the Office is charged with setting record management standards in accordance with applicable laws and regulations, as well as recognized best practices.

In addition to compliance with university’s record management policy, the Office of Medical Education has adopted the Guidelines for Maintaining Active and Permanent Individual Student Records developed by the Association of American Medical College’s (AAMC) Committee on Student Records (COSR).

Certiphi Screening CBC information is maintained electronically for six years and do not become a part of the student education record.

Access to this information will be limited to the Vice Dean of Medical Education, the Associate Dean for Admissions, the Office of Admissions, and the Associate Dean of Student Affairs or their designees.

The results of Live Scan Fingerprinting are the property of the LAC+USC Department of Human Resources. Keck does not receive a copy of the results.

Resources

Fair Credit and Reporting Act

The federal Fair Credit Reporting Act (FCRA) promotes the accuracy, fairness, and privacy of information in the files of consumer reporting agencies.

A Summary of Your Rights Under the Fair Credit and Reporting Act

Vertical Screen, Inc.

Through its subsidiary, Certiphi Screening, Inc., provides pre-employment and pre-contractual background checks to employers and other organizations. The following information will assist consumers to:

Order a free copy of their credit report in accordance with the FACT Act;
Order a free copy of your own Background Screening Report (if one was processed by Certiphi Screening, Inc. upon your authorization to a Certiphi Screening, Inc. client)
Dispute the Accuracy of a Background Screening Report generated by Certiphi Screening, Inc.
Obtain contact information for Certiphi Screening, Inc.

Reviewed and Approved by the Medical Education Executive Council

November 4, 2020