Form CHRC 103 is completed by the authorized person at a New York healthcare facility, not by the applicant, to request a state and federal criminal history record check on a prospective employee. The authorized person collects the applicant’s personal and identification details, records the fingerprinting information, and submits the data electronically through the Health Commerce System. Before any of that happens, the applicant must sign a separate consent form (CHRC 102).
Sign the CHRC 102 First
Nothing goes into the state system until the prospective employee has signed DOH Form CHRC 102, “Acknowledgement and Consent for Fingerprinting and Disclosure of Criminal History Record Information.” The signed consent has to be in hand before any data is entered.1New York State Department of Health. DAL 20-04 – CHRC Requirements and Best Practices
Keep the signed CHRC 102 in the employee’s file even if the person is never hired. Submitting the 103 data before the consent is signed, or backdating a consent to cover a submission already made, creates a compliance gap that can invalidate the entire check during a state audit.
Who Fills Out Form CHRC 103
The form instructions are explicit: “This form is to be completed by the Authorized Person.”2NYS Department of Health. NYS Department of Health Form CHRC 103 Facility administrators grant authorized person access through the “Manage AP” function inside the CHRC application on the Health Commerce System.3New York State Department of Health. Background Check Requirements for Health Homes and Care Managers
When a staffing agency places a worker at a facility, responsibility for completing the form stays with the facility, though the staffing agency may complete Section 4 if it handles the fingerprinting. Every field in every section should be filled in before or at the time of fingerprinting.
Section 1: Subject Individual Information
Section 1 captures the applicant’s identifying details: last name, first name, middle initial, maiden name, and any aliases, along with date of birth, Social Security Number, home address, phone numbers, sex, race, country and place of birth, height, weight, hair color, and eye color.
Two points to get right. First, providing the Social Security Number is voluntary. The DOH CHRC Unit uses it to match records more accurately, but the applicant cannot be required to provide it.2NYS Department of Health. NYS Department of Health Form CHRC 103 Second, the name entered on the form must exactly match the name and spelling on the photo ID the applicant will bring to fingerprinting. Nicknames, shortened names, or misspellings can delay the process or cause the applicant to be turned away at the fingerprinting appointment.1New York State Department of Health. DAL 20-04 – CHRC Requirements and Best Practices
Section 2: Subject Individual Identification
The applicant must present two forms of identification. At least one must be a government-issued ID with the applicant’s signature, and at least one must contain a current photograph. Acceptable government-issued IDs include a valid driver’s license or DMV identification card, a valid passport, valid military identification, or a valid school identification document.2NYS Department of Health. NYS Department of Health Form CHRC 103 Record the ID type, issuing authority, ID number, and expiration date for each document.
Section 3: Agency Identification
In Section 3 the authorized person identifies the facility: type (nursing home, certified home health agency, licensed home care services agency, and so on), license number, PFI number, and full agency name and address. The authorized person then signs and dates this section personally, confirming they collected the applicant’s information and verified their identity.
Section 4: Fingerprinting Method and Identification
Section 4 records the fingerprinting details: whether ink-and-roll or Livescan was used, the name and address of the fingerprinting location, whether identification was verified, and the date fingerprinted. The person who performed the fingerprinting signs this section. If the facility handles fingerprinting directly, the authorized person completes it. If a staffing agency fingerprints the applicant, the staffing agency fills in Section 4.
Submitting Through the Health Commerce System
Form CHRC 103 data is entered electronically through the DOH’s Criminal History Record Check application, housed within the Health Commerce System at hcsinfo.health.ny.gov.3New York State Department of Health. Background Check Requirements for Health Homes and Care Managers After the authorized person enters the data and clicks Submit, the system generates a confirmation, the 103 submission receipt. Print it and put it in the employee’s file. Page 2 of the physical Form CHRC 103 must also be forwarded to the DOH CHRC Unit.
Keep the CHRC 102 consent form, the 103 submission receipt, and any subsequent termination forms in the file for every applicant, including those who are never hired.3New York State Department of Health. Background Check Requirements for Health Homes and Care Managers Facilities that treat these records as disposable risk findings during state surveys.
Scheduling Fingerprinting After Submission
Once the 103 submission goes through and the CHRC application generates a Request for Live Scan, the authorized person and the applicant should schedule a fingerprinting appointment within seven days. The approved vendor is IdentoGO by IDEMIA (formerly MorphoTrust). Appointments can be booked at uenroll.identogo.com or by calling (877) 472-6915. The service code for CHRC fingerprinting is 154552.4New York State Department of Health. Mandatory Background Check Requirements for HCBS Providers
The applicant needs to bring three things to the appointment:
- The same government-issued photo ID recorded in Section 2 of the CHRC 103.
- Payment, typically covered by the employer through an NCAC (Non-Criminal Applicant Card) or other form of payment the employer provides.
- The Request for Scan Services printout from the CHRC application, which the authorized person provides.
Livescan captures digital prints and transmits them electronically to the Division of Criminal Justice Services and the FBI for cross-referencing against state and federal criminal records.2NYS Department of Health. NYS Department of Health Form CHRC 103 A 2009 DOH letter listed the total fee at $105.75 ($94.25 for the DCJS and FBI review plus $11.50 for vendor processing).5New York State Department of Health. Dear Nursing Home Administrator Letter – CHRC Live Scan Implementation The current fee may differ; confirm the amount through the CHRC application or with IdentoGO when scheduling.
Processing Time and Starting Work Before Results Arrive
For applicants with no criminal history on file, processing runs roughly seven to ten days. Cases involving a record take longer because the DOH must review the specifics before issuing a determination. If the check reveals a felony charge without a final disposition, DOH holds the application until the charge is resolved.
Facilities do not have to wait for results before putting someone to work. A prospective employee can receive temporary approval and begin working while the CHRC is pending, provided the temporary employee does not provide direct care without supervision by a staff member whose own check has cleared or by exempt licensed staff.3New York State Department of Health. Background Check Requirements for Health Homes and Care Managers If the pending check involves an unresolved felony charge, the temporary employee may work but cannot provide direct care or supervision to patients or residents at all. The DOH sends the final determination to the employer through the HCS portal.
Mistakes That Delay a CHRC 103
Most delays trace to a small set of avoidable errors:
- Name mismatch between the CHRC application entry and the applicant’s photo ID, down to a missing middle initial or misplaced hyphen.
- Submitting the 103 before the applicant has signed the CHRC 102.
- Letting the fingerprinting appointment drift past the seven-day window after the Request for Live Scan is generated.
- Using an IdentoGO service code other than 154552, which can route the prints to the wrong agency.
- Leaving fields blank. The instructions require every field in every section to be completed, including ones that look optional.
Who the CHRC Requirement Covers
Not every hire at a healthcare facility triggers a CHRC 103. Public Health Law Article 28-E applies the requirement to specific providers including residential health care facilities such as nursing homes, certified home health agencies, licensed home care services agencies, long-term home health care programs, hospice programs certified under Article 40, and adult homes, enriched housing programs, and residences for adults licensed under Article 7 of the Social Services Law. Health homes and their subcontractors serving enrollees under twenty-one are also covered.6New York State Senate. New York Code PBH 2899 – Definitions
Within those providers, “employee” means anyone employed or used by the provider (including temporary staffing agency workers) who will provide direct care or supervision to patients or residents. Licensed professionals under Title 8 of the Education Law, such as registered nurses, physicians, and physical therapists, are excluded, and so are volunteers.7New York State Senate. New York Consolidated Laws, Public Health Law PBH 2899 Certified nursing assistants, home health aides, dietary workers, and other hands-on staff without a Title 8 license need a CHRC.