NETStudy 2.0

Providers and entities are now using NETStudy 2.0 which includes use of: 

• Scanned electronic fingerprint images to identify possible state criminal records instead of using name and date of birth.
• Photographs to verify the identity of the subject.
• Data from the Minnesota Court Information System (MNCIS) to automatically notify DHS of new state criminal information for people who are affiliated with entities.
• Links to professional health and human service licensing and registration information in Minnesota and other states.
• A portal  for study subjects to enter  their own background study demographic  information.

Use of NETStudy 2.0 improved background studies in the following ways:

• Improved accuracy 
  
  • NETStudy 2.0 uses fingerprints for Minnesota criminal record searches rather than name and date of birth. When name and date of birth was used, DHS received many false "hits" on people with the same or similar name as a background study subject. Additionally, the Bureau of Criminal Apprehension estimated that DHS missed about one percent of individuals' criminal records due to name-based checks.. Use of fingerprints addresses these issues.
  • DHS receives automated updates of state criminal information from the Minnesota Court Information System (MNCIS).  Prior to this, DHS relied on manual reports from entities, corrections agents, and probation officers. The MNCIS information helps maintain the validity of previously completed background studies.
  • Entities can verify the identity of the background study subject by the person's photograph in NETStudy 2.0.

• Increase efficiencies and provide faster results for entities and background study subjects 
  

• People with cleared background studies who submitted fingerprints, photos, and Social Security Numbers in NETStudy 2.0 can begin providing direct care services immediately in most circumstances.
• Entities are able to verify other data using information in NETStudy 2.0, including state and federal lists of people who have committed fraud against programs and are prohibited from affiliation.
• Entities receive electronic notices of background study determinations. This replaces mailing notices through the USPS.

• Added data privacy protections  

• The law authorizing the background study changes prevents DHS and the Minnesota Bureau of Criminal Apprehension from keeping the fingerprints. The law also limits how long DHS can keep photos.
• The law allows people to request destruction of background study data and provides timelines for auto destruction of data.
• The law requires fingerprint and photo service locations to meet data security standards and only keep limited information for billing and auditing purposes.
• Background study subjects are given a comprehensive privacy notice that informs them of their rights, including the right to request a report on who accessed their background study status.
• Data, including fingerprints and photographs, are transmitted through secured IT systems. Data maintained in NETStudy 2.0 is encrypted and subject to strict state and federal data protection laws.

• Addressed issues in the previous background study system 
  

• Background studies were connected to the entity that submitted them. This required workers to have a new background study determination processed with each job change to update the background study information including state criminal information.
• People with common names often experienced delays in getting their study completed due to the extra research necessary to ensure that the applicant was the person in the study.
• New criminal history information was provided only when an entity, corrections agent or probation officer reported it.
• It was time intensive and costly to mail notifications to entities regarding background study results and to call entities to verify whether a person was hired or still working (i.e.,is currently affiliated).

The bill that amended the Department of Human Services Background Studies Act - Minnesota Statues, chapter 245C was signed into law by Governor Dayton on May 16, 2014. The legislation was passed unanimously in both the House and Senate. The law supported the background study enhancements, including requiring the use of fingerprints to complete state criminal record checks.  Expansion of FBI authority was not included in the final amendment that was passed in 2014.  

The amended law for the background study enhancements did not change who was required to have a background study, when it was to be submitted, or what may disqualify a person. 

• Provides a more comprehensive background study that is updated if new criminal or maltreatment information is received which helps protect people who use health and human services. 
• Supports continued receipt of state offender status.  Fingerprints are required in order to continue to receive information from the Minnesota Bureau of Criminal Apprehension that lets DHS know that a background study subject may have criminal information in another state.  This information is available when the person also has a record with the Minnesota Bureau of Criminal Apprehension (BCA).  The information has been provided for many years, but would have been stopped if DHS did not transition to use of fingerprints. 
• Updates IT security features for better data protection and more refined user controls and monitoring. 
• Provides the infrastructure needed for additional streamlining and modernization of processes. For example, DHS plans to import data from NETStudy 2.0 into background study letters so they can completed faster for background study subjects and providers.   
• Can be used to complete national background checks, including receipt of updated FBI data if legislation is passed to permit this.  
• Eliminates the use of paper fingerprint cards with some very limited exceptions as requested by entities or background study subjects. 

• More accurate and comprehensive background studies that are updated as new information becomes available through automated processes.
• Immediate access to clearance notices in some cases.  Determinations for background study subjects with a cleared study in the NETStudy 2.0 system (that includes fingerprints and a photograph), are available to an entity in real-time, if the background study subjects provided their Social Security numbers for a previous background study. Note: There are some transfer-ability restrictions based on specific requirements for certain programs, such as child foster care.
• Assurance that the person applying for a position is the individual for whom the background study determination applies, because the person's photograph is view-able in NETStudy 2.0.
• Gained administrative efficiencies such as more efficient communication with entities and elimination of the need for certain paper files.
• Elimination of ‘employment verification’ phone calls for people who are on NETStudy 2.0 rosters.

• Allows most background study subjects with a cleared background study to be hired immediately (when the study is fingerprint-based with a photo and the person’s Social Security Number is included).
• Eliminates "repeat" background study determinations in nearly all situations when the study subject provides fingerprints, a photo, and his/her Social Security Number.
• Provides a secure method for people to enter their own demographic information when this option is selected by a provider or entity.

• Fingerprints and photos required 

When fingerprints and a photograph are required for background studies, they must be completed at a DHS authorized location. The fingerprint and photo process should take about five-to-ten minutes and is completed by a trained technician. The fingerprint images are transmitted through a secure system to the Minnesota Bureau of Criminal Apprehension (BCA) and in some cases when required by law, the fingerprints are also transmitted securely to the Federal Bureau of Investigation for a criminal record search. Criminal history results, if any, are then electronically sent to DHS.

• Map of fingerprint and photo service locations 

You can find fingerprint locations near you by selecting the region you are in on the map. This will take you to a list of locations that includes the address and hours available for fingerprinting.   

If you want to save the URL, save this one of the map of locations.  If you save a specific region or location’s information, the URL will not update and you may miss important change information, such as location closures or changes in hours. 

• Fingerprints and photo fee and vendor information 

The fingerprinting and photo service fee is $9.10 at all DHS authorized locations. In most cases, this is a one-time process in a person's career for a DHS background study.

Information about fingerprint and photo locations, including addresses and hours of operation, is available on  Cogent's webpage.

• Information for background study subjects 

You may select from over 60 statewide locations to have your fingerprints and photo taken. A list of the fingerprint and photo service locations is available on the Cogent website. The entity that initiated your background study will give you a Fingerprint Authorization Form that includes the information you need for the fingerprint and photo service.

When you go to the fingerprint and photo service location you MUST bring both your Fingerprint Authorization Form AND your driver's license, government-issued ID, or other acceptable form of identification. 

It is very important to be sure that your name and date of birth on the Fingerprint Authorization Form is exactly the same as the information on your identification.

If the information on the Fingerprint Authorization Form does not match your identification document, contact the place that requested the background study and have them correct it. If the information on the form does not exactly match your identification, you will be turned away at the fingerprint and photo location.

You have up to 14 days to be fingerprinted and photographed. Sometimes the place that requested the background study wants you to go sooner. Let the place that requested your background study know if there is a reason that you cannot go to be fingerprinted and photographed in the 14 day period.

If the place that requested your background study did not pay for the fingerprinting and photo service, you will need to pay the $9.10 fee. Payment can be made:

1. Online using a credit or debit card at Cogent; this site can also be accessed using mobile devices

2. By phone using a credit card or debit card by calling the  Cogent Call Center toll free at 1-844-332-7671 Monday through Friday from 8 a.m. to 5 p.m. CST; or

3. At the fingerprint and photo location by check or money order. Cash is NOT accepted at the fingerprint and photo locations.

• Fingerprint and photo retention
Fingerprints are not retained by DHS or the BCA, but will be retained by the Federal Bureau of Investigation (FBI) in cases where an FBI check is required. Photographs are transmitted through a secure system to DHS and are available in NETStudy 2.0. Fingerprints and photo images are not retained by or available to the fingerprint and photo service location.

• How fingerprints will be used
The fingerprints will be used to obtain criminal history information on the background study subject from the Minnesota Bureau of Criminal Apprehension and in some cases, the FBI.. An FBI record check is required for people whose:

• Minnesota BCA record indicates there is or may be  criminal records in another state;
• Background study is  required to provide child foster care;
• Background study is part of a home study for adoption;
• Background study is required for a health occupation practitioner license or registration issued by the Minnesota Department of Health;  
• Address is outside of Minnesota and they will be providing services for a nursing home, home care agency, or boarding care setting.

The fingerprints will not be retained by DHS or the BCA. If the fingerprints are submitted to the FBI, the FBI retains them.

• Entities interested in purchasing equipment for fingerprinting and reporting fingerprinting problems

• Information is available on the Gemalto Cogent web site, including this summary.  

• Fingerprint vendor, issues, or problems

3M Cogent was selected as the statewide fingerprint vendor for DHS background studies in 2014 through a competitive bidding process.  3M subsequently sold its identity management services (including its fingerprinting services) to Gemalto, an international business in digital security

• Since Gemalto’s purchase of the fingerprint service in early 2017, more fingerprint locations have been added.  Most of these have been in the Twin Cities metro area where there is the highest volume of transactions.  A list of the current fingerprint and photo service locations is available on the Gemalto Cogent website.
• You may report problems or concerns with the fingerprint service to dhs.netstudy2@state.mn.us.  DHS staff follow-up with Gemalto Cogent on reports.  

Email dhs.netstudy2@state.mn.us to request an account. Background Study Division staff will send you the information needed to establish a NETStudy 2.0 account.  The process includes completion of two electronic forms and the information includes instructions on how to complete the process.  

1. The Authorized Agent who is a license holder, controlling individual, or managing employee must complete and return a systems access agreement. That agreement also identifies who the background study sensitive information person (SIP) will be for each license or program.  The same person can be the SIP for all or some of the licenses or programs.   

2.  The SIP will then receive a system access agreement that must be completed and returned.  

After these forms are returned to DHS electronically, user accounts are established for the SIP and the SIP receives two emails. One email has account access information and the other email has the person’s password. The emails are sent separately for added security. 

Entities can add users and control their level of access in NETStudy 2.0. Once the SIP account is established, the SIP has control over the entities users and can add accounts based on what the user will be doing in the system.  Information on how to setup these accounts can be found the NETStudy 2.0 Onboarding Guide.  The guide was developed for entities that were transitioning from the prior NETStudy system.  However, entities that are opening NETStudy 2.0 accounts may find the guide helpful.  Additional training materials are under the HELP feature in the NETStudy 2.0.

Additionally, a YouTube video was developed to assist entities in the transition to NETStudy 2.0.  The video describes the overall process and options about how entities may want to design their background study sensitive information structure.  Entities that are establishing a new NETStudy 2.0 account may find much of this information helpful.   

If you are not sure whether your program or entity is required to submit background study requests to DHS, you may review Minnesota Statues, subd. 245C.03.  

Or, you may contact the authority that issues your license or registration. This is usually the DHS Licensing Division or the Department of Health.  In some cases, it is the Department of Transportation or the Department of Corrections.  For unlicensed services under DHS, contact Provider Enrollment or Group Residential Housing policy.  

There are some background studies that DHS completes under contracts or other agreements. These account for a very small portion of background studies some of these have not transitioned to NETStudy 2.0, including studies conducted for: 

• Guardians and Conservators
• Guardians ad litemPeople seeking to adopt a child 
• Some Tribal Governments (for child foster care and adoption)
• MNsure navigators
• Minnesota Adult Abuse Reporting Center (MAARC) staff 

NETStudy 2.0 training is web-based and free. There are several YouTube videos available that demonstrate how to initiate a background study request in NETStudy 2.0 as well as all other key features of the system. It is easiest to follow along with the videos after you have a NETStudy 2.0 account.

Training materials also include the NETStudy 2.0 User Manual that provides detailed instructions, including screenshots and user tips about how to use NETStudy 2.0 and the NETStudy 2.0 Quickstart Guide that provides screen shots to show users how to enter a background study request.

• Entities must complete the process when they are notified by DHS.  Entities will have a minimum of 45 days to finish.  Large entities, including hospitals and providers with fifty or more licenses, will have 180 days to finish.  .  
• DHS worked with entities to test and provide feedback on options for the import process.  Modifications were made to the system based on their feedback and DHS received positive feedback with this process. 
• The process is not expected to identify matches for all people who are uploaded.  A “reprocessing” feature is available in the system when there may be a match to an existing valid background study.
• If entities are not able to find a match and successfully import the record to their roster, a new background study of the person is required.  
• The system logic is comprehensive to account for variations in name, mistakes in uploaded data, etc.  In these cases, the reprocessing feature may be used.  
• There is no limit on the number of times an entity may use the reprocessing feature.   
• The upload process will involve close to 17,000 providers, tens of thousands of actively affiliated background study subjects’ records, and 4.5 million records in DHS’ database.  Because of the scope and size of the project, background studies staff will not be able to check or verify individual case questions or match issues. 
• DHS will also not provide copies of background study letters or notices, including copies of the “mailers” printed on colored paper that include background study ID numbers.  Entities are responsible for maintaining these documents.   There is one exception to this for people whose most current background studies were completed in or after 1995 and before 2000. 

Exception.  Background study staff will provide background study numbers  for  people whose most recent background study was completed in or after 1995 (when all background studies were required to be updated) and before 2000.  This is because there is no background study number on the background study notice for these individuals.  There is additional information in the NETStudy Import Process User Guide and a form in the appendix to use to request the background study numbers in this cases.  

Benefits of completing the process – It is required 

There are several reasons complete NETStudy 2.0 rosters are important, including that:

• It is the way that background records that were completed in the original NETStudy system are affiliated to the entities’ active rosters.  
• DHS is notified electronically of new state criminal information for individuals who are affiliated on active rosters.   If the new information results in a change to a person’s background study determination, the entity will be notified based on having the person actively affiliated on its roster.  This is necessary to keep the background study valid and transferable.
• Continued receipt of maltreatment determinations.  If the new information results in a change to a person’s background study determination, the entity will be notified based on having the person actively affiliated on its roster. 
• DHS will notify the entity if a person on actively affiliated its roster is added to the state or federal exclusion list. The federal list is referred to as the List of Excluded Individuals and Entities (LEIE).
• It eliminates the need for DHS to call entities to verify whether a person is affiliated.  

Several training and technical assistance support options are available at no cost. Most are web-based and available at any time. Training and support materials, including a comprehensive user guide, You Tube videos.

• NETStudy Roster Import Process User Guide. There is a comprehensive user guide that provides detailed instructions, including visual aides.  To access it go to the HELP feature in NETStudy 2.0 and it is in the HELP drop-down options (available 2-12-18). 
• YouTube Videos.  There are a series of seven YouTube videos that provide instructions on the required steps in the roster import process.  To access the video links go to the HELP feature in NETStudy 2.0 and it is in the HELP drop-down options (available 2-12-18). 
• WebEx support.  WebEx conference calls will be held three to five times per week for the first three months of implementation and possibly longer.  During the calls, participants may submit questions and NETStudy 2.0 staff will respond to as many as possible during the hour-long sessions.  This is the most effective and timely way to receive responses to your questions.  These calls will not include demonstrations because that information is covered in the YouTube videos and user guide.  To access the WebEx call information and schedule go to the HELP feature in NETStudy 2.0 and it is in the HELP drop-down options (available 2-12-18). 
• Phone tree.  Directions to resources covering some common questions will be available in a phone tree by calling 651-431-6625.   There will not be an option to speak with a background studies staff member or to leave a voice message about the import process.  Questions will be answered through the WebEx conference calls. 
  • NETStudy 2.0 email and help desk line.  Please do not submit import processquestions to the NETStudy 2.0 email box or call help desk line.  Questions submitted to the dhs.netstudy2@state.mn.us email box requesting checks or verification about individual case questions or match processing issues will not receive responses.  Likewise, contacts to the background study help desk concerning these questions will be directed to the training materials and WebEx calls.   This permits staff time to be directed to background study questions and issues that affect current workers and students, and for which there are not specific written resources or technical assistance materials.  

 Implementation time line and notice to begin.

Entities will be contacted during 2018 to start the import process.  The background study sensitive information person (SIP) will be contacted by email and provided detailed information.  In general, the notice process is automated in NETStudy 2.0 and is not manually controlled by background study staff.   This means that staff will not be able to inform you when your entity will need to begin the process and it is not based on provider type because most programs provide services under more than one program type.  

However, large providers (i.e., those with more than 50 licenses/organization numbers) and hospitals are expected to receive the notice to begin the import process before May 2018.  This is because these programs have six months to complete the process.  All other entities have 45 days to complete the process.  

Answers to many questions can be found in this searchable PDF of frequently asked questions (PDF).

Currently, FBI record checks are only required for certain background studies.  In the present system, information from the BCA can identify when criminal history records may exist in another state. However, the information is only available if the person also has a criminal record in Minnesota and the record check is completed using the person’s fingerprints. This means that some people with criminal records in another state may clear a background study because DHS is not informed of those records. If FBI record checks were required for all background studies, criminal records in other states would be reported to DHS even if the person did not have a criminal record in Minnesota.

The benefits of including FBI record checks for all background studies is to receive criminal history information, if applicable, from other states for background study subjects that do not have a record with the BCA.  This provides a more comprehensive study.  Additionally, for some providers, it would eliminate the need for completing additional background checks and the related costs.  

It also would provide the opportunity to receive updated criminal history information (sometimes referred to as rap back) from the FBI if a background study subject affiliated with an entity committed a crime in another state.  

Changes in state law would be required to expand FBI record checks and FBI rap back.   

DHS pursued feedback from stakeholders for developing the new NETStudy 2.0 system beginning in 2013. The feedback was used to design the new background study process and the related legislative amendments. Additionally, DHS staff attended conferences and meetings throughout 2014 and 2015 to share information about the background study changes and solicit feedback and ideas. Beginning in fall 2014, many of these presentations and meetings included demonstrations of NETStudy 2.0 in development.

State-wide meetings 
Between July and October 2014, DHS held overview and feedback meetings in nine statewide locations. A recording of the presentation is available online as a  YouTube video and PowerPoint presentation.

Fingerprint Survey
In October 2014, 3M Cogent opened a survey to entities and background study subjects to provide feedback about the statewide fingerprint and photo service. Results of that survey are available online.

Pilot Group
In July 2014, DHS worked with a group of providers licensed by the Minnesota Department of Health to pilot test NETStudy 2.0. DHS later expanded the pilot by adding several programs licensed by DHS. On April 6, 2015, the pilot providers began submitting fingerprint based background study requests in NETStudy 2.0. Several enhancements to NETStudy 2.0 have been made based on feedback from these pilot providers.

DHS pursued and was awarded a $3 million grant by the U.S. Department of Health and Human Services' Centers for Medicare & Medicaid Services (CMS) in August 2012 to enhance the background study program. The National Background Check Program (NBCP) helps entities avoid hiring individuals with certain criminal histories by conducting federal- and state-level criminal background checks on people who provide health and human services.

DHS identified five goals for using the funds:

1. Collect scanned fingerprints on all subjects of background studies, including developing the capacity to collect fingerprints statewide, and transmit the images electronically for processing
2. Use fingerprints to match subjects with state criminal records via the state BCA, replacing the use of names and birth dates
3. Design and automate a process so DHS is notified when the subject of a previous background study commits a crime in Minnesota that may result in disqualification
4. Include automated checks of the federal Office of Inspector General exclusion list, professional licensing and disciplinary boards, other states' nurse aide registries, and predatory offender registries, and expand state background checks to include Minnesota's predatory offender registry
5. Expand the number of background study subjects on whom a record check is conducted with the FBI to identify records that may exist in other states.

Goals one-through-three are met, and most of goal four is met with the implementation of NETStudy 2.0. Goal five requires legislative authorization to expand FBI record checks.

DHS’ grant was extended through July 2018.  Until that time, work on systems enhancements and additional functions will continue. 

Updates about the changes to background study processes and implementation of NETStudy 2.0 are communicated through notices in the system and to people on the background study email list. You can subscribe to the background study email list.

Questions about the background study changes and NETStudy 2.0 may be submitted to dhs.netstudy2@state.mn.us