Providers delivering behavioral and therapeutic services to New Jersey FamilyCare members must complete a new FBI fingerprint-based background check, or risk being ineligible to provide services. The New Jersey Division of Medical Assistance and Health Services (DMAHS) recently issued guidance requiring Applied Behavior Analysis (ABA), Developmental Individual Differences Relationship-based (DIR), Behavioral Assistance (BA), and Intensive In-Community (IIC) providers to complete an FBI fingerprint-based background check in order to provide services to New Jersey FamilyCare (NJFC) members. All background checks must be completed by April 26, 2026.
New background checks must be run on all providers by the deadline. Providers in an ABA or related agency may not provide direct, face-to-face services to NJFC members without passing this background check.
How the Background Check Works
The FBI background check is provided at no cost to NJFC-contracted providers and must be completed through the Employment Controls and Compliance Unit (ECCU) within DHS’s Office of Program Integrity and Accountability (OPIA).
The background check must be repeated every two (2) years. The ECCU will continue to resubmit fingerprints for providers every two (2) years if they receive a timely archiving request from the employing agency.
Background Checks for Existing Providers
Prior fingerprints are not transferable and cannot be used to satisfy this requirement. New background checks must be run on all providers by the deadline. Existing providers who were previously fingerprinted, including those fingerprinted for professional licensure, must be re-fingerprinted under the new federal process. Licensing boards are not permitted to share fingerprint results with DMAHS.
Scheduling Your Background Check
Providers must use new service code forms when scheduling FBI background checks. ABA and DIR providers should coordinate directly with ECCU, while BA and IIC providers must contact the Children’s System of Care (CSOC) to obtain the required service code forms. All new providers, as well as individuals with pending state-only background checks, must be fingerprinted using the new FBI service codes.
Required Actions
- All ABA, DIR, BA and IIC providers must pass new federal background checks through ECCU no later than April 26, 2026 to continue providing direct services to NJFC members.
- Agencies should review their current onboarding and credentialing processes to ensure compliance and confirm that no direct services are being delivered by individuals who have not passed the FBI background check.
Should you have any questions regarding the above, please contact the authors, the Garfunkel Wild attorney with whom you regularly work, or contact us at [email protected].
