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Transition from emergency studies to full compliance

Beginning Sept. 15 the Department of Human Services will resume fingerprint-based background studies for 16 provider types with federal compliance requirements. Other provider types are expected to resume fingerprint-based studies for new subjects in phases from Nov. 3 through Nov. 17. Beginning Dec. 1, DHS will accept resubmissions for fully compliant studies for those with emergency studies.

During the COVID-19 pandemic, the Department of Human Services (DHS) temporarily modified background studies beginning April 6, 2020. This included temporarily suspending fingerprint and photo requirements. DHS has until July 2, 2022 to transition to fingerprint-based studies; emergency studies remain valid until that date. DHS will notify providers through GovDelivery as dates are set to resume fingerprint-based studies and will frequently update this page.

Transition timeline

DHS is transitioning to fingerprint-based studies in stages for various provider types to allow DHS and entities to more smoothly resume the fully compliant studies for new hires and those with emergency studies. In addition to returning to fingerprint-based studies, a new vendor will be providing fingerprint and photo services. 

This is the timeline for the various provider types with the expected dates for resuming fingerprint-based studies for new hires and resubmitting studies for individuals who received emergency studies:

Emergency studies continue

DHS continues to conduct emergency background studies and providers do not need to take any action until they are notified. Emergency studies remain valid until July 2, 2022 -- 365 days after the end of the peacetime emergency, which occurred July 1, 2021.

The Governor’s Executive Order 20-12 (PDF) gives the human services commissioner authority to temporarily suspend or modify many of the background study requirements to assist health and human service providers to quickly respond to the changing workforce needs while maintaining the health and safety of the clients they serve. 

Instructions with steps and information entities need to submit an emergency background study are available on NETStudy 2.0. Details about emergency background studies are also provided in frequently asked questions about emergency background studies.

Once entities return to fingerprint-based background studies, they will now longer be able to submit emergency studies. 

Emergency studies valid through transition 

Emergency studies remain valid through July 2, 2022. 

As fingerprint-based studies resume, new employees will be required to have a fingerprint-based study. Individuals who received emergency studies will also need to have a fully compliant study by July 2, 2022 to continue to work after that date. Providers should prioritize new hires. DHS will work with providers after Dec. 1 as it begins to accept resubmissions for fully compliant studies for those with emergency studies.  The emergency studies will remain valid until July 2, 2022. 

All emergency background studies specify “COVID-19 Study” in the final determination status. For example, if the study subject is determined eligible, the study subject’s final determination status will be “Eligible-COVID-19-Study.”  

New vendor for fingerprints and photos

As fully compliant background studies resume, a new vendor (IDEMIA) will fingerprint and photograph study subjects at locations statewide. DHS chose IDEMIA Identity & Security USA LLC (IDEMIA) through a competitive bidding process with cost, quality and reliability of their enrollment center locations considered in proposal evaluations. The basic components of the fingerprinting process will remain the same, with a few differences, including online pre-enrollment, described in frequently asked questions about the transition to IDEMIA.  

Information for entities resuming fingerprint-based studies

As DHS resumes fingerprint based studies for provider types, they will be required to submit fingerprint-based studies for all new hires and newly affiliated study subjects. Providers will no longer be able to submit emergency studies.

Changes for child care providers

With the resumption of fingerprint-based background studies, child care providers will return to submitting enhanced background studies for new hires, newly affiliated individuals and individuals who were not able to complete an enhanced study during the statewide rollout in late 2019 and 2020. Minors may not be required to submit fingerprints. For detailed information, including coverage of costs by DHS and FAQs, visit Minnesota child care provider background studies.
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