California Code § 1596.871(c)(1)(A): Criminal Background Clearance

📋Type B Violation🏢Affects: Child Care Centers

What Is California Code § 1596.871(c)(1)(A): Criminal Background Clearance?

California Code § 1596.871(c)(1)(A)

Subsequent to initial licensure, a person specified in subdivision (b) who is not exempt from fingerprinting shall obtain either a criminal record clearance or an exemption from disqualification, pursuant to subdivision (f) of this section or Section 1522.7, from the State Department of Social Services prior to employment, residence, or initial presence in the facility. A person specified in subdivision (b) who is not exempt from fingerprinting shall be fingerprinted. The licensee shall submit fingerprint images and related information to the Department of Justice and the Federal Bureau of Investigation, through the Department of Justice, or comply with paragraph (1) of subdivision (h), prior to the person's employment, residence, or initial presence in the child day care facility. The department shall not require the person to disclose their criminal history information prior to receipt of live scan results.

💡Insider's Tips

This is the citation inspectors write when they find anyone in your facility who started before their live scan results came back. 'Prior to employment, residence, or initial presence' means exactly that: the person cannot be in the building in any working capacity until clearance is confirmed. Start the live scan process the day you make a verbal offer, not after onboarding paperwork. Results typically take 5 to 15 business days but can stretch to 4 weeks if there is anything on the record that requires review. Build that timeline into your hiring process. Also note that you cannot ask applicants about their criminal history before the live scan results arrive. According to California CCLD records, 62 facilities were cited for this across 22 counties in the past 90 days.

64
facilities cited recently
That's 1 in 667 facilities
22
counties affected
5
most common citation
📉
Decreasing
Last 90 days vs. previous 90 days
64 facilities (was 84)20 facilities

Source: California CCLD inspection records | Data: last 90 days as of Feb 16, 2026

How to Avoid Criminal Background Clearance Citations

✓ Prevention Checklist

❌ Common Mistakes

  • Letting a new hire 'shadow' or 'observe' before their clearance arrives. Providers think if the person isn't technically working alone with children, it's fine. The law says prior to initial presence in the facility, and shadowing counts as presence. Inspectors will cite this.
  • Assuming a clearance from a previous employer transfers automatically. Each facility must initiate its own clearance process through the CDSS. A clean record at another center does not exempt you from filing new fingerprints, though you can use the transfer process if the prior clearance is still active with the department.
  • Confusing live scan submission with live scan clearance. Submitting fingerprints does not mean the person is cleared. The clearance letter from CDSS is what counts. Providers sometimes let someone start after the fingerprint appointment, which is still a violation.
  • Not tracking associate clearances for household members in family child care homes. The requirement covers anyone who resides in or is regularly present at the facility, not just employees. A new roommate or adult family member moving in triggers the same fingerprinting requirement.

What's Being Cited in Each Region Over the Past 90 Days

Based on facility inspection reports filed with California's Community Care Licensing Division, here's how this citation appears across different regions in the past 90 days.

Los Angeles County

9 citations

San Diego County

8 citations

San Francisco County

6 citations

Orange County

5 citations

Riverside County

5 citations

Santa Clara County

5 citations

San Joaquin County

3 citations

San Luis Obispo County

3 citations

Kern County

2 citations

Marin County

2 citations

Data updated weekly from CCLD public records. Last update: 2/16/2026

See California Code § 1596.871(c)(1)(A): Criminal Background Clearance Citations in Your County

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Frequently Asked Questions

What is Criminal Background Clearance?
Criminal Background Clearance requires that every person working in, residing at, or regularly present in your childcare facility obtain a cleared criminal record check from CDSS before they set foot in the building in any working capacity. This applies to employees, volunteers, and household members in family childcare homes. For your operations, this means building live scan processing time (typically 5 to 15 business days, sometimes longer) into every hiring timeline.
How common is this citation?
According to California CCLD inspection records as of February 08, 2026, 62 facilities have been cited for this violation in the past 90 days across 22 California counties. That's roughly 1 in 645 inspected facilities. Los Angeles leads with 9 citations, followed by San Diego (8), San Francisco (5), Orange (5), and Marin (4). This is a high-severity finding that inspectors take seriously given the child safety implications.
What triggers this citation during an inspection?
Inspectors compare employee hire dates or start dates against the date on the criminal record clearance letter from CDSS. Based on CCLD inspection patterns, the citation is written when anyone started working before their clearance letter arrived, including people who were just 'shadowing' or 'observing.' Submitting the live scan fingerprints is not the same as being cleared. Inspectors also check for household members in family childcare homes who lack clearance documentation.
How can I prevent this citation?
Start the live scan process the day you make a verbal job offer, not after onboarding paperwork. Build 3 to 4 weeks into your hiring timeline for results. Never let a new hire shadow, observe, or help out before the clearance letter arrives from CDSS. Keep the original clearance letter in the person's personnel file. If you transfer a clearance from a previous employer, confirm the transfer is active with the department before the person starts.
What should I do if I receive this citation?
Immediately verify the cited individual's current clearance status with CDSS. If they have since been cleared, file the documentation and include it in your plan of correction. If clearance is still pending, the person cannot be present at the facility until it arrives. Document your corrected hiring process showing the timeline from offer to live scan to clearance to first day. For complex situations, consider consulting a licensed childcare compliance specialist.

Related Violations

This information is educational and does not constitute legal advice. Consult a licensed childcare compliance consultant for guidance specific to your facility. Citation data is sourced from California Community Care Licensing Division public records and is refreshed regularly.