Criminal Background Check Policy

National concerns regarding the suitability of health care providers have caused many hospitals and other institutions that provide health care services to require disclosure of an individual’s criminal history. As of 2004, the Joint Commission, an organization that accredits healthcare organizations in the United States, requires criminal background checks for security purposes for all employees, staff and volunteers who supervise care, render treatment and provide services. Many state statues also require disclosure of an individual’s criminal history in order to apply for certain health care licenses/permits/certificates/registrations. Additionally, existence of a criminal history may subject an individual to denial of initial licensure, permit, registrations, revocation or suspension of existing licenses or denial of access to training sites used by the School of Pharmacy.   

The primary role of the pharmacist is to provide safe and effective health care to the patients served. Patient safety must be considered in the selection and education of student pharmacists. The School also has a responsibility to maintain as safe an environment as possible for its students and the practice settings in which they receive education. Therefore, to promote safety and the highest level of integrity in the profession of pharmacy, the School of Pharmacy requires matriculating students to submit to a criminal history background check.  

1. All applicants and matriculating students are to submit to a criminal background check prior to matriculation. In addition, students who remain enrolled must submit to a criminal background check annually to remain eligible for continued matriculation. Some students may be required to undergo fingerprinting as part of the criminal background check process as part of applicable state law. The initial and annual criminal background check will be conducted by the Certiphi, Inc. or another School of Pharmacy approved vendor.
2. Additional criminal background checks may be required by health care facilities at which the student will be participating in educational activities as a component of the curriculum or state agencies relevant to the education of the student.
3. Students must disclose all criminal convictions (felony and misdemeanor) regardless of whether or not the felony conviction was subsequently reduced to a misdemeanor. Failure to disclose a conviction, or material misrepresentation of information, is deemed to be falsification of the application and will result in denial of matriculation and/or dismissal from the School and University.
4. Failure to comply with the request to undergo a criminal background check within the stipulated timeline will result in dismissal from the School or revocation of the offer of admission.
5. Students with a positive criminal background history are individually responsible for checking the licensing requirements of any state other than the state of Maryland where the student is interested in participating in clinical rotations to determine whether or not their conviction may be a barrier to participation.
6. The School of Pharmacy does not guarantee clinical rotations or any other off campus activity for students who have a history of felony or misdemeanor convictions. In such cases, the School will confidentially share information about the student’s positive criminal background history with potential preceptors and practice site representatives as necessary and on a need-to-know basis and gives the preceptor and site representatives an opportunity to decide whether the student is acceptable to the site. Therefore, scheduling and completion of clinical rotations and graduation may be delayed. In some instances, it will not be possible to arrange for clinical rotations at specific sites.
7. Students are required to disclose to the dean any arrests, criminal charges or convictions against them during their entire period of enrollment as a student at the School of Pharmacy. Such arrests, criminal charges, or convictions may negatively impact a student’s ability to obtain and/or complete program requirements.
8. All costs are the responsibility of the student.

Procedure

1. All accepted and matriculated students will be required to undergo a criminal background check by the School of Pharmacy approved vendor, Certiphi, Inc. Newly admitted students will be given a copy of the School’s Criminal Background Check Policy.
2. Certiphi, Inc. will contact the student directly to obtain the necessary information to initiate the search.  Students will receive an email from studentedition@certiphi.com.
3. Upon completion of the search, results will be released to the student who can view the information securely online. The student will have the opportunity to view the information and to resolve any disputes directly with the vendor. After 10 calendar days, the report will be automatically released to the School.
4. The office of admissions will review all criminal history reports and if a history of a felony or misdemeanor conviction exists, the director of admissions in consultation with the dean or her designee, will determine whether or not the student should be disqualified from matriculation or continued enrollment. Criminal convictions will not automatically disqualify a student from enrollment or continued enrollment. The School will consider such factors, but not limited to, the nature of the crime, the age of the individual at the time the crime was committed, length of time since the conviction, relevance of the conviction to health care. In determining the impact and relevance of the conviction, the following information, but not limited to, may be requested:
   1. Additional detailed information about the positive criminal background check report.
   2. Consultation with state licensing agencies about the impact of the misdemeanor or felony conviction on the student’s ability to undertake/resume clinical activities.
   3. Collection of additional data, e.g., Federal Bureau of Investigation fingerprints and report, concerning the positive criminal background check.
   4. Court charging documents or other official records pertaining to the charge and/or conviction.
5. If a positive criminal history is known by the School prior to or after the student’s matriculation, the dean or her designee will meet with the student to discuss the consequences of the positive criminal background investigation on the student’s ability to enter or complete the program and graduate so that appropriate action can be taken.
6. Continuing students’ annual criminal background check will be reviewed by the assistant dean for student affairs and if criminal charges or convictions are noted, the assistant dean in consultation with the dean will determine if continued enrollment as noted in 4 above.
7. Printed records concerning a student’s positive criminal background check are stored in a locked confidential file in the office of the dean.