Background Checks - Character, Competence, and Suitability (CC&S) Review


A CC&S determination is a review process used, when required, to decide whether an individual may have unsupervised access to minors or vulnerable adults. 

The determination is based on a review of available information (RAP sheets (when applicable), personal knowledge, self-disclosures, etc.) about the individual and is most often completed as part of the background check process. A CC&S may be completed at other times as well.

The decision as to whether the applicant/employee may or may not have unsupervised access to minors or vulnerable adults must be documented as part of the CC&S review.

When a CC&S is Required

A CC&S review and determination is required when:

  • An individual has a Review Required background check result that includes non-disqualifying:
    • Conviction(s),
    • Pending charge(s),
    • Negative action(s);
  • There are concerns about an individual related to client(s) health and safety, or other risks to the client(s);
  • There is a reasonable, good faith belief that the individual cannot meet the care needs of the client(s);

A CC&S determination can never be used to allow a provider to work when the individual has automatically Disqualifying:

  • Conviction(s),
  • Pending charge(s),
  • Negative action(s)

Factors considered when making a CC&S determination

These factors include, but are not limited to, the following:

  • Whether you have a reasonable, good faith belief that a provider would be unable to meet the care needs of the client. 
    • E.g., if the provider would be responsible for driving the client, and have multiple DUIs.
  • Vulnerability of the client under the provider’s care.
  • Behaviors since the convictions, charges, negative actions or other adverse behaviors.
  • Pattern of offenses or other behaviors that may put the client at risk. 
    • E.g., if they would be working for a client with dementia, and have recent theft convictions. 
  • Number of years since the conviction, negative action, or other issue.
  • Whether the provider self-disclosed the conviction (s), pending charge(s) and/or negative action(s).
  • Other health and safety concerns.

Documenting your decision

After careful review of the information about the applicant/employee, the department or entity documents on the CC&S form for HCS/AAA/HCRR/Home Care Agency or for RCS that they have determined the individual:

  • May have unsupervised access to minors or vulnerable adults; or
  • May not have unsupervised access to minors or vulnerable adults; or
  • For HCS only, does not have the character, competence or suitability to work with a specific client (for example, excessive commuting distance).
  • After the CC&S form is completed, it should be maintained according to your program rules. Please do not submit a copy to BCCU.