Background Investigations for Child Care Workers, GSA Form 176

Homeland Security Presidential Directive (HSPD) 12 “Policy for a Common Identification Standard for Federal Employees and Contractors” (the Directive) requires the implementation of a government-wide standard for secure and reliable forms of identification for Federal employees and contractors. OMB’s implementing instructions requires all contract employees requiring routine access to federally controlled facilities for greater than 6 months to receive a background investigation. The minimum background investigation is the Tier 1 and the Office of Personnel Management offers a Tier 1C for childcare. However, there is no requirement in the law or HSPD-12 that requires childcare employees to be subject to the Tier 1C since employees of childcare providers are neither government employees nor government contractors. The childcare providers are required to complete the criminal history background checks mandated in the Crime Control Act of 1990, Pub. L. 101-647, dated November 29, 1990, as amended by Pub. L. 102-190, dated December 5, 1991. These statutes require that each employee of a childcare center located in a Federal building or in leased space must undergo a background check that is: 1) based on fingerprints taken by a law enforcement officer and on other identifying information, 2) conducted through the FBI's Identification Division and through the State criminal history repositories in each state in which the childcare employee has been a resident or has listed in an employment application, and 3) initiated through the personnel program of the applicable employing agency. According to GSA policy childcare workers (as described above) will need to submit the following: 1. An original signed copy of a Basic National Agency Check Criminal History, GSA Form 176; and 2. Two (2) sets of fingerprints on Form SF-87 and /or electronic prints from an enrollment center 3. Electronically submit the e-QIP (SF85) application for completion of the Tier 1C

The latest form for Background Investigations for Child Care Workers, GSA Form 176 expires 2027-12-31 and can be found here.