Platt College is Becoming Part of Concordia University, St. Paul

Revision Responsibility: Dean of Nursing

Responsible Executive Office: President

Purpose: The purpose of this policy is to define Platt College’s policy for background checks.  For a variety of reasons, students enrolled in Platt College’s nursing program, a program that requires off-campus field-based assignments such as clinical rotations, are required to submit to a criminal background check following acceptance, but prior to their admission to the program.  Accepted applicants’ background checks must be received within 10 days of notification of acceptance.  Delayed receipt of completed background check may result in the applicant’s acceptance being revoked.  Failure of any portion of a program's required checks may be the basis for barring the student from admission or completion of that specialized program, depending on the findings and based upon the current nursing program's requirements.

Platt College’s implementation of background checks for students is primarily in response to various affiliates'/agencies' requirements for accepting students for clinical rotations. These affiliates/agencies include, but are not limited to, clinics, hospitals, health facilities, pharmacies, community-based organizations, or local, state or federal agency requirements. If a clinical affiliate/agency or other organization requires the checks prior to accepting Platt College students, the college must comply. At Platt College, it is required that the college will conduct the background check at the student's expense.  Platt College reserves the right to request another background check at any point in a student’s program.  Additionally, a drug screen is required for all nursing students upon admission, annually, randomly, and/or at the discretion of the clinical affiliate/agency.  Students who perform clinical assignments for a Children’s Hospital are required to be finger-printed. Other clinical affiliate/agencies may also require fingerprinting.

Platt College requires background checks as a condition of admission or acceptance for clinical rotation and may do so because:

• students have significant interaction with minors and vulnerable populations;
• students who cannot successfully complete a background check may not, in some instances, be eligible for licensure, certification, or employment upon graduation;
• students may be eligible to take the NCLEX examination but there is no guarantee of licensing.

Accepted applicants to Platt College’s nursing program will be denied admission without successful completion of a seven-year criminal background check. Admission status is assigned upon successful completion of the background check.

The final repository of the official criminal background checks is located in the College's secure learning management system, My Platt College; however, the student may be asked to upload the background check into other technology solutions to meet the individual requirements of clinical affiliates/agencies.. Records requests for release, copies, etc. should be directed to the Executive Administrative Assistant in writing. Students will be required to sign an Informed Consent/Release for Criminal Background Investigation for potential release of their background checks to Platt College in addition to a Disclosure and Release Form available from www.plattcollegecx.com.    

In order to be accepted into certain affiliates (hospitals/medical centers) for clinical placements, students may also be required by such hospitals/medical centers to submit to additional checks including, but not limited to, drug screens, Social Security number trace for previous residencies, employment checks, Office of Inspector General (OIG) Sanctions List, General Services Administration's Excluded Parties Listing System (GSA/EPLS), violent sex offender and predator registry search, applicable state exclusion list, US Treasury Office of Foreign Assets Control (OFAC), and the list of specifically designated nationals. Whether such additional checks will be required and the procedures for conducting the same, will be the sole responsibility of the affiliates (hospitals/medical clinics) requiring them. Platt College does not conduct such additional checks unless specifically agreed to by the particular program.

Definitions:

Clinical affiliate/agency - An affiliate who, by agreement with Platt College, provides clinical education experiences for Platt College students.

Background Check - Background checks include the State of Colorado and the nation.

Scope:

This policy applies to all undergraduate nursing students that are required by conditional admission, field experience, and clinical affiliation.

Policy:

A. Admission

1. Some of Platt College’s programs may require a criminal background check as part of admission to a program or prior to any field-based experience.
2. Admission to a program and field placement is contingent upon satisfactory results of a criminal background check. Refusal to provide consent for a criminal background investigation will result in denial of admission.

B. Admissions, Field Experience, and Clinical Placement, Dismissal

1. Criminal background information released to a program will be used only for purposes of assisting in making programmatic decisions.
2. If a background check identifies issues that may preclude admission, field experience, or clinical placement, the case will be referred to the College President for review and action.
3. If a background check identifies issues that the accepted applicant considers inaccurate or incomplete, these concerns or issues must be addressed by the accepted applicant, to the State Criminal Information Bureau for resolution.  It is not Platt College’s responsibility to rectify any background inaccuracies on the accepted applicant’s behalf. 
4. Licensure. Since licensure is a requirement to practice nursing and there are questions as to whether a student's criminal history, if any, will prevent or restrict his/her ability to obtain a license in nursing, the student should discuss the matter prior to application to the program with the Colorado Board of Nursing at http://www.dora.state.co.us/Nursing.  Students may be eligible to take the NCLEX examination but there is no guarantee of licensing.

C. Admission, Clinical Education, Field-Based Experience, Waiver/Consent

1. Applicants will be informed at the time application materials are received by them and after successful completion of the programmatic entrance exam that a criminal background check will be required if the decision is made to admit the applicant.  A criminal background check that reveals a conviction of a felony or other serious offense(s) that would likely prevent or restrict the student's ability to obtain a license in the field of study may result in the revocation of the student's admission.
2. Clinical Education. Students will be required to successfully complete a criminal background check prior to placement in off-campus sites for clinical training. Each student background check is reviewed by each clinical site and must meet that site’s specific regulations and requirements. Conviction of a felony or other serious offense may result in a student being denied a clinical assignment, and consequently, dismissal from the program. However, the acceptance or rejection of a student for a clinical assignment based upon the criminal background check is ultimately a decision of the officials of the clinical site.
3. Waiver/Consent. Students who are seeking application will need to submit an Informed Consent/Release Form and Disclosure and Release Form to complete a criminal background investigation. 

D. Obtaining a Criminal Background Check

1. For the School of Nursing at Platt College, the background check must be initiated by the student as part of the routine admission process.  Platt College must receive the completed background check before official acceptance into the Program. 
2. All expenses associated with the background check are the sole responsibility of the requesting student.
3. The Informed Consent/Release of Criminal Background Investigation Form and Disclosure and Release Form must be signed and returned to the Executive Administrative Assistant by the requesting student.

E. Background Check Package

1. Social security number trace and residential history
2. Statewide or county criminal history record search (current residence)
3. Nationwide sex offender registry search
4. Federal criminal history record search
5. Office of the Inspector General (OIG) Sanction Report
6. General Services Administration (GSA) Excluded Parties List search
7. Office of Foreign Asset Control (OFAC) Terrorist List search
8. Professional license verification – applicable only for accepted applicants that hold a CNA, LPN, EMT, or Paramedic License

F. Convictions

1. If an applicant truthfully discloses conviction(s) on the application for admission or clinical placement, an evaluation of each conviction will be made before admission or clinical placement is granted.
2. The existence of a conviction does not automatically disqualify an individual from admission or clinical placement. Relevant considerations may include, but are not limited to, the date, nature and number of convictions; the relationship the conviction bears to the duties and responsibilities of the profession; and successful efforts toward rehabilitation. Any final decision to reject or accept an applicant with a conviction is solely at the discretion of the College President or in the case of clinical placement, the clinical affiliate/agency.
3. Failure to disclose all previous convictions other than minor traffic convictions will be considered falsification of records and may be grounds for denying admission or placement.
4. Students must disclose any new charges or convictions to the Associate Dean within 30 days of the incident occurring.  Failure to do so may result in disciplinary action up to and including dismissal from the Program.
5. If the College becomes aware that a current student has not completed the application truthfully, he/she may be subject to disciplinary action up to and including dismissal from the Program.
6. The following criminal histories may disqualify an individual for consideration for program admission or clinical placement:
   • Any violent felony convictions of homicide. (No time limit)
   • Crimes of violence (assault, sexual offenses, arson, kidnapping, any crime against an at-risk adult or juvenile, etc.) as defined in section 18-1.3-406 C.R.S. in the 10 years immediately preceding the submittal of application.
   • Any offense involving unlawful sexual behavior in the 10 years immediately preceding the submittal of application.
   • Any crime, the underlying basis of which has been found by the court on the record to include an act of domestic violence, as defined in section 18-6-800.3 C.R.S. in the 7 years immediately preceding the submittal of application.
   • Any crime of child abuse, as defined in section 18-6-401 C.R.S. in the 7 years immediately preceding the submittal of application.
   • Any crime related to the sale, possession, distribution or transfer of narcotics or controlled substances in the 7 years immediately preceding the submittal of application.
   • Any felony theft crimes in the 7 years immediately preceding the submittal of application.
   • Any misdemeanor theft crimes in the 5 years immediately preceding the submittal of application.
   • Any offense of sexual assault on a client by a psychotherapist, as defined in section 18-3-405.5 C.R.S. in the 7 years immediately preceding the submittal of application.
   • Crimes of moral turpitude (prostitution, public lewdness/exposure, etc.) in the 7 years immediately preceding the submittal of application.
   • Registered Sex Offenders. ( No time limit)
   • Any offense in another state, the elements of which are substantially similar to the elements of any of the above offenses.
   • More than one (1) D.U.I. in the 7 years immediately preceding the submittal of application.

If the investigation reveals information that could be relevant to the application, the designated individual responsible for background checks may request additional information from the applicant. The offense shall be reviewed on a case by case basis. Students who have successfully completed the terms of a deferred adjudication agreement will not be disqualified.

If any applicant feels the criminal background check is inaccurate, they may appeal the decision and request a review. It is the applicant’s burden to produce substantial evidence that proves the crimes charged are incorrect.

For purposes of this policy, the term "conviction" will be interpreted broadly and will include pleas of no contest, withheld judgments, suspended sentences, and similar dispositions. If a criminal history report indicates pending criminal charges that, if a conviction resulted, would result in exclusion from admission, field experience, or clinical placement, the candidate may be excluded from admission, field experience, or clinical placement pending the final disposition of the charges.

F. Results

1. Confidentiality. Efforts will be made to ensure that results of criminal background checks are kept confidential with the number of persons authorized to review results limited on a need to know basis.
2. Access to Results. The company conducting the background check will provide the results to the Dean, School of Nursing. The Dean, School of Nursing will review all criminal background checks. If the results contain adverse information deemed to be relevant to the applicant's suitability for his or her program, the Dean, School of Nursing will notify the applicant. The Dean, School of Nursing will make any final decisions relative to admission or field experience and the clinical affiliate will make a final decision on clinical placements, if required by the clinical affiliate. Results may be reviewed, as appropriate, by the professional staffs, (excluding student employees), of the Program, Department and clinical affiliates.
3. Information Available Through Background Checks. If the check reveals information that could be relevant to a student's status in the program, the program may request additional information from the applicant..
4. Right to Respond to Adverse Report. The applicant will be asked to review any adverse information and to provide a written response to the program. When appropriate, the applicant may be asked to meet with the Dean, School of Nursing in person to answer questions.
5. Right to Change and/or Terminate Policy. Reasonable efforts will be made to keep applicants informed of any changes in the policy. However, the College reserves the right, in its sole discretion, to amend, replace, and/or terminate this policy at any time.

a. Clinical affiliates/agencies may have the discretion to determine whether a student's background is acceptable, if deemed necessary according to the clinical affiliates’ policy.

b. Since background checks may be done at different times during a program, additional or updated background checks may be required prior to the beginning of the clinical or didactic portion of the program.

c. Students will be afforded notice and the opportunity to be heard prior to any program's action or dismissal in accordance.  Notwithstanding any other College or student appeal process, this procedure shall be the exclusive and final procedure available to the student. However, if the student is challenging the accuracy or completeness of the criminal background records, a final decision regarding the student's status will be delayed pending the results of the challenge.

d. Retention. Individual background checks will be kept by Nursing Admissions Coordinator in accordance with Platt College’s Policy 03:03:00 Confidentiality of Student Records Policy.

e. Students have 30 days to notify the Dean or Associate Dean of Nursing of a charge or conviction that occurs while they are enrolled in nursing school at Platt College. If notification to the School of Nursing is not made and a change in background status is discovered, the student may be terminated from the program. 

Timeframe and Application:

Valid and cleared background checks that have been previously completed will only be accepted within six months of the student’s official start date. All background checks must be completed through American DataBank.

G. Compact and Single-state Licensing

As of January 18, 2018 any nurse applying for a new RN license in Colorado will need to obtain a fingerprint background check as part of the application process. The compact law does not provide the applicant the option to choose between a compact license or a single-state license. All Colorado applications are processed according to compact requirements.

If there is a "hit" or flagged item on the background check, the review process can take additional time, up to and including review by the State Board of Nursing. These hits do not automatically exclude someone from license eligibility, but a felony conviction would exclude someone from a compact license. In these cases, the Board may consider whether or not an individual would be eligible for a single-state, Colorado only, license.

Revised: August 4, 2009, Revised: January 17, 2011 to reflect revised organizational chart, August 5, 2014 to update college titles, and to include community-based organizations and local, state, or federal agency requirements, June 17, 2016, to reflect change in Background Check timeline in relation to the Admissions Process and to specify the clinical sites ability to reject a student based on their specific regulations, March 22, 2017 to include CCCS Disqualifying Offenses list. Revised June 29, 2018 to reflect new Board of Nursing (DORA) approach to compact licensing in regards to flagged background checks.