University of Southern California

USC Policy

Employment and Workplace

Date issued: June 22, 2012

Criminal Background Screening

The university is committed to providing a safe work environment; to that end, the university mandates that individuals holding certain positions and serving in some capacities are excluded from employment or participation in certain specified roles or programs if they are found to have been convicted of certain specified crimes. The individuals described in this policy must undergo criminal background screening prior to employment or beginning work in certain programs; and, in accordance with university guidelines, are subject to additional screening during employment.

Only the Senior Vice President for Administration, the Provost and Senior Vice President for Academic Affairs, or their designee(s) can authorize additional criminal background screenings for staff, faculty, students, volunteers or others. Only the Senior Vice President for Administration, the Provost and Senior Vice President for Academic Affairs, or their designee(s) can authorize individuals or departments, or engage contractors, to conduct such screenings. With such authorization, some departments may require additional screening beyond that described in this policy.

Specific Screening Requirements

All staff: Criminal background screening is conducted prior to and as a condition of employment; with individuals subject to additional screening in accordance with departmental requirements. A conviction for any crime listed in Appendix A may be considered in the decision whether to exclude these individuals from an offer of employment or continued employment; individuals with convictions may only be employed or continue to be employed if approved by the Assistant Vice President for Talent and Organizational Effectiveness or Associate Senior Vice President for Human Resources.

Staff providing clinical services: In addition to the screening requirement noted above for all staff, staff employees providing clinical services are subject to screening at least annually, and more often at the university's discretion, against the federal Office of Inspector General's (OIG) List of Excluded Individuals/Entities and federal General Service Administration's (GSA) Excluded Parties List System. Individuals screened include, but are not limited to, hospital personnel including: hospital employees, clinical staff employees, volunteers, travelers, Sodexo employees, Stericycle employees, USC security employees, USC contracted pharmacists, and USC contracted therapists. These screenings relate to exclusions from the Medicare, Medi-Cal and other federal health care programs (see Appendix B).

All part-time faculty: Criminal background screening is conducted prior to and as a condition of employment, with individuals subject to additional screening in accordance with university guidelines. A conviction for any crime listed in Appendix A may be considered in the decision whether to exclude these individuals from an offer of employment or continued employment; individuals with convictions may only be employed or continue to be employed if approved by the Provost in consultation with Faculty Affairs.

Clinical faculty at the Keck School of Medicine (i.e., any faculty member from any clinical discipline within KSOM who treats patients as part of his or her profile of activities): Criminal background screening is conducted prior to and as a condition of employment, with individuals subject to additional screening in accordance with university guidelines; individuals with convictions may only be employed or continue to be employed if approved by the Provost in consultation with Faculty Affairs. Clinical faculty who apply for privileges and credentials through the USC Care Integrated Credentialing Service are also screened against the federal Office of Inspector General (OIG) List of Excluded Individuals/Entities and federal General Service Administration (GSA) Excluded Parties List System, prior to initial credentialing, monthly and at reappointment. These screenings relate to exclusions from the Medicare, Medi-Cal and other federal health care programs (see Appendix B). Screenings also are performed at initial credentialing and re-credentialing (every 2 years) with Versys (historical verification of OIG/GSA sanctions), Federation of State Medical Boards, Medilert (malpractice/insurance) and the American Medical Association.

Clinical faculty at the Herman Ostrow School of Dentistry (i.e., faculty who apply for privileges and credentials through the HOSOD Credentialing Service): Criminal background screening is conducted prior to and as a condition of employment, with individuals subject to additional screening in accordance with university guidelines; individuals with convictions may only be employed or continue to be employed if approved by the Provost in consultation with Faculty Affairs. Screening against the federal Office of Inspector General's (OIG) List of Excluded Individuals/Entities conducted prior to initial credentialing and at reappointment, and more often at the university's discretion. These screenings relate to exclusions from the Medicare, Medi-Cal and other federal health care programs (see Appendix B).

Faculty, staff and volunteers assigned to work in a program designed specifically for minors: A conviction for any crime in Appendix A (especially any crime of a sexual nature as listed in Section V) may be considered in the decision whether to exclude these individuals (including tenured, tenure-track, and non-tenure track appointments) from working in a program designed specifically for minors. Screening will be conducted prior to assignment, with individuals subject to additional screening in accordance with university guidelines. For staff, individuals with convictions may only be assigned to programs involving minors if approved by the Assistant Vice President for Talent and Organizational Effectiveness or Associate Senior Vice President for Human Resources. For faculty, individuals with convictions may only be assigned to programs specifically designed for minors if approved by the Provost in consultation with Faculty Affairs.

For all staff, faculty and volunteers working in a program specifically designed for minors, if a previous background screening cannot be verified, if it is more than 7 years old, or at any other time at the department's discretion, the individual is subject to a new screening.

Additional Considerations

Any individual who has provided inaccurate or misleading information on his or her employment application with regard to identity, convictions, or education and/or certifications, will be considered ineligible for hire, continued employment, or service.

Responsible Office

Talent Management

(213) 740-9464

Vice Provost for Faculty Affairs

Issued by

Elizabeth Garrett, Provost and Senior Vice President, Academic Affairs
Todd R. Dickey, Senior Vice President, Administration
University of Southern California