VA Keeps Childcare Hires on Background Check Leash
Published Date: 11/21/2025
Notice
Summary
The Department of Veterans Affairs is renewing a rule that requires background checks for anyone hired to provide childcare services to kids under 18. This keeps kids safe and applies to all contracts involving childcare, education, or related services. Comments on this renewal are open until December 22, 2025, with no new costs or changes planned.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Mandatory background checks for VA childcare hires
If you work or apply to work providing childcare, education, social services, health/mental health care, day care, or rehabilitative programs under a VA contract, you must undergo a criminal history background check for any role that serves children under age 18. This requirement comes from the Crime Control Act (34 U.S.C. 20351) and must be included in all VA solicitations, contracts, and orders that involve services to children under 18.
VA contractors must perform background checks; time burden noted
If your business contracts with the VA to provide services to children under 18, you must include VAAR clause 852.237-73 in all solicitations, contracts, and orders and ensure all existing and new contract employees undergo criminal history background checks. The VA estimates an annual burden of 1,500 hours total, with an average of 60 minutes per respondent and an estimated 1,500 respondents (one response per contract employee).
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