The Consolidated Eligibility Letter System (CELS)

According to 45 CFR § 98.43 each state lead agency that conducts the child care background checks must provide the requesting child care provider with a response to identify if a prospective or current child care employee is eligible to work with children or ineligible to work with children, based on all required background checks. The prospective or current child care employee or child care provider will submit an application for a consolidated eligibility letter (CEL). The finalized CEL will be sent to the child care provider and prospective or current child care employee. All background check details will still be mailed to the prospective or current child care employee, per the requirements in the Child Protective Services Law (CPSL).

The requirements of 45 CFR § 98.43 can be found here.

A presentation from the Office of Child Care on the requirements is available here.

Beginning on September 23, 2024, an applicant or provider can apply for a CEL using the Consolidated Eligibility Letter System (CELS). The CEL will indicate that the applicant is ‘eligible’ to work or ‘ineligible’ to work with children. 

Prospective or current child care employees who need their criminal background checks renewed or need the initial background checks will go to the CELS website to apply using the new Consolidated Eligibility Letter System (CELS).  The applicant or provider will identify on the application where the CEL should be sent.

Child care employees with current child care criminal background results on file will not need to apply for a new CEL until their earliest child care criminal background result expires. At that point they will need to apply for clearances through the CEL process. New hires who need to obtain their background checks, as well as employees who need to update their background checks prior to January 1, 2025, may begin using the CEL process on September 23, 2024. Beginning, January 1, 2025, all employees who need to obtain or update their background checks must do so through the CEL process.

If the Head Start provider is a DHS-licensed child care provider, employees must also adhere to 45 CFR § 98.43 and obtain a CEL.

No. The federal regulations do not require volunteers to obtain the consolidated eligibility letter. 

Child care volunteers must continue to adhere to the PA CPSL background check requirements by obtaining:  

• The Federal Bureau of Investigation (FBI) Criminal History clearance; 
• The National Sex Offender Registry (NSOR) verification; 
• The PA State Child Abuse History; 
• The PA State Police (PSP) Criminal History background check; and
• Any out-of-state background checks, if applicable.

Child care employees with current child care criminal background results on file will not need to apply for a new CEL until their earliest child care criminal background result expires. At that point they will need to apply for clearances through the CEL process. New hires who need to obtain their background checks, as well as employees who need to update their background checks prior to January 1, 2025, may begin using the CEL process on September 23, 2024. Beginning, January 1, 2025, all employees who need to obtain or update their background checks must do so through the CEL process.

Yes, the child care employee will continue to receive the results of each clearance and verification. The CPSL requires that the employer maintain a copy of all required documents.

Yes, child care providers will still need to maintain a copy of the detailed background check results to comply with requirements in the CPSL. Additionally, providers must maintain a CEL to comply with the federal requirements. OCDEL certification staff will check for this documentation, therefore these documents must be kept in the employee’s personnel file.

Yes. If an applicant has a current CEL and begins employment at a new child care provider, the new child care provider may request a duplicate CEL if certain conditions are met. Prior to making a request for a duplicate CEL, the provider must obtain an affirmation in writing from the employee that the employee has not been:

1. Charged or convicted of a criminal offense that would disqualify them from working or residing in a child care setting. 
2. Named on the National Crime Information Center National Sex Offender Registry or on any state's sex offender registry.
3. Named on a Statewide database or its equivalent as a perpetrator of child abuse.
4. Separated from employment in a child care setting for more than 180 days

OCDEL certification staff will check for this documentation, therefore the affirmation must be kept in the employee’s personnel file.

The CEL is valid for 60 months (five years) from the date of issuance. Per federal regulations, if an individual experiences a lapse in employment in a child care center, group child care home or family child care home that exceeds 180 days within this five-year period, a new CEL will be required.  Additionally, if one or more individual clearances expire during this five-year time frame, a new CEL will be required. 

Please review question and answer #12 for additional details related to individuals who have a valid CEL and are transitioning to a new employer.

The following background checks are included in the CEL eligibility determination:

• Federal Bureau of Investigation (FBI) Criminal History clearance. 
• Federal National Sex Offender Registry (NSOR) verification. 
• PA State Child Abuse History. 
• PA State Police (PSP) Criminal History (includes the PA sex offender registry check). 
• Out-of-State Criminal History background, if applicable.
• Out-of-State Sex Offender Registry, if applicable; and
• Out of State Child Abuse and Neglect Registry, if applicable.

The Office of Children, Youth and Families Clearance Verification Unit (CVU) will review the results of these checks to determine if an individual is “eligible” or “ineligible” to work or reside in a child care setting based on the CPSL and federal regulations.

Both the child care provider and child care employee may initiate a request for the CEL.  If the child care provider submits this request, the child care employee will need to provide written consent to the child care provider.  Documentation of this written consent must be kept in the employee’s personnel file.  

Eligibility determinations will be made within 45 days of the CEL application being received as required by 45 CFR §98.43. The CEL will be mailed no later than 45 days after the application is received. In order to comply with the CPSL, employees will continue to receive their individual background check results as they become available. 

An individual may be employed on a provisional basis in a child care center, group child care home or family child care home when:

• The CEL application has been completed in its entirety and submitted to the CVU;
• The applicant receives the results of the National Sex Offender Registry verification, PA State Child Abuse History and either the PSP Criminal History or FBI Criminal History clearance; and
• The applicant swears or affirms in writing that they are not disqualified from employment.

In addition to the above requirements, employees who live outside of Pennsylvania or who have lived outside of Pennsylvania within the preceding five years must also submit the results of their out-of-state background checks prior to commencing employment.

An employee hired on a provisional basis must not be left alone with children and must work in the immediate vicinity of a permanent employee. If the remaining results are not obtained within 45-days, the employer must dismiss the employee or move them to a position where they do not have “direct contact with children” as contained in the definition of “child care services” in the CPSL pursuant to 23 Pa. C.S. § 6303 (relating to definitions) and 6344 (m) )(relating to provisional employees for limited periods) of the Child Protective Services Law. 

The total cost for obtaining a CEL will be $59.95. If out-of-state (OOS) clearances are required and depending on the state, additional costs may be incurred. In most instances, the applicant will submit their OOS application and payment directly to the OOS agency. If the OOS agency is a closed-state agency only then the Clearance Verification Unit is required to request the OOS clearance on the applicant’s behalf. To initiate this process the applicant must submit the OOS paper application to the Clearance Verification Unit along with a check or money order for the amount required to run each additional component of the OOS check. 

Out-of-State background checks are required anytime an employee has lived outside of Pennsylvania within the last five years. There are THREE required out-of-state background checks:

1. Out-of-State Criminal History Check;
2. Out-of-State Sex Offender Registry Check*; and
3. Out-of-State Child Abuse and Neglect Registry Check.

*NOTE: Each state has the option to use a fingerprint to conduct the sex offender registry check so this will vary from state to state. Additional information on each state’s requirements can be found here https://childcare.gov/state-resources-home.

While the Federal Office of Child Care allows name-based criminal history checks to be completed for out-of-state check purposes, some states only process criminal history checks using a fingerprint-based process. If a state requires fingerprints for a criminal history check, an applicant must be fingerprinted using a hard card. 

Per the CPSL at §6344(m): Employers, administrators, supervisors, or other persons responsible for employment decisions may employ applicants on a provisional basis for a single period not to exceed 45 days.

If the remaining results are not obtained within 45-days, the employer must dismiss the employee or move them to a position where they do not have “direct contact with children” as contained in the definition of “child care services” in the CPSL pursuant to 23 Pa. C.S. § 6303 (relating to definitions) and 6344 (m) )(relating to provisional employees for limited periods) of the Child Protective Services Law.

Per the CPSL, grounds for denying employment or participation in program, activity or service in a child care setting can be found at §6344(c).

Per Federal regulations, grounds for denying employment in a child care center, group child care home or family child care home can be found at 45 CFR §98.43(C)(1).

Per the CPSL, disqualifying crimes can be found at §6344. (c)(2).

Per Federal regulations, disqualifying crimes can be found at 45 CFR §98.43(C)(1)(iv). 

The child care employee is responsible for paying for the CEL.  However, a child care provider may offer to pay for the CEL for their employees and may purchase a payment code.  Child care employees should talk to their employer to determine payment arrangements. 

If an individual wishes to obtain a paper CEL application, they may choose between the following methods:

• An individual may also contact the Clearance Verification Unit by calling 717-783-6211 or toll free at 1-877-371-5422 to request an application be emailed or mailed to them. 
• An individual may visit the Clearance Verification Unit located at 2525 7^th Street, Harrisburg, PA 17110 and request a paper CEL application.  

Individuals who have questions relating to obtaining a CEL may contact the Clearance Verification Unit by calling 717-783-6211 or toll free at 1-877-371-5422.

Child care providers who have questions relating to licensing requirements pertaining to the CEL, may contact their appropriate Office of Child Development and Early Learning Bureau of Certification Regional Office.  The contact information for the Regional Offices can be found here:  Regional Child Development Offices (pa.gov)

Compliance with the CEL requirements will be determined by the applicable Office of Child Development and Early Learning Certification Representative.