Compliance & Rules | Sentinel Four Team
Key points
In the Self-Determination Program (SDP), a caregiver who gives direct personal care cannot start work until a criminal background clearance is complete. This article covers who needs one, who is exempt, who pays, how the fingerprinting works, and why "start Monday, clear later" is not an option.
Who needs a clearance
As of 2026 the Department of Developmental Services (DDS) requires criminal background clearance for:
- any caregiver hired by the participant, or by the family on the participant's behalf, who provides direct personal care, and
- any caregiver of a non-vendored provider who provides direct personal care.
"Non-vendored" means a provider who is not vendored with a regional center. The SDP rule is aimed at people the participant hires directly and at providers outside the regional center vendor system.
The clearance has to be in place before the person starts. Not before the first paycheck. Before the first shift.
Who is exempt
Family members who live in the same home as the participant are exempt from the background check requirement. The exemption is about the household, not the relationship: a sibling who lives elsewhere is not exempt. Whether a specific living arrangement counts as the same home is a question for the regional center.
Being exempt from the background check does not exempt anyone from the rest of onboarding. Employment documents, wage notices, timekeeping and payroll apply to everyone. See Can a Family Member Be Paid as a Caregiver Under SDP?.
Who pays
The provider pays for their own background check. That is the DDS rule as of 2026. For a caregiver hired by the participant, that means the caregiver. The cost is not paid from the individual budget.
How the process works
The Financial Management Service (FMS) directs the caregiver to fingerprinting. In California this is done through Live Scan, an electronic fingerprint capture at an approved location. The general sequence:
- The FMS gives the caregiver the correct request form and instructions. Using the wrong form or the wrong agency code sends results to the wrong place, which means starting over.
- The caregiver takes the form to a Live Scan location, pays the fee, and is fingerprinted.
- The fingerprints go to the state, and the results are routed to DDS.
- DDS reviews and issues a clearance decision. Questions about a specific clearance go to DDS at sdpbackground@dds.ca.gov.
- The FMS receives confirmation that the person is cleared and can be onboarded.
How long it takes depends on the state's processing and on whether anything on the record needs review. Plan for weeks, not days, and build it into your hiring timeline. See Hiring Your First Caregiver Under SDP.
Why a caregiver cannot start before clearance
Families sometimes ask whether a caregiver can start while the clearance is pending and be paid once it comes through. No, for three reasons:
- The DDS rule says clearance is needed before starting. A shift worked before clearance is a shift that was not allowed under program rules.
- The FMS cannot pay for hours that were not authorized. Payroll runs only for people who are onboarded, on an approved spending plan, and authorized. A pre-clearance shift does not meet that test, so it cannot be paid from the budget.
- Safety is the point. The rule exists to protect the participant, and the clearance is the only evidence anyone has that the check was done.
If a caregiver has already started informally, tell your case manager and service coordinator immediately so the situation can be corrected, rather than letting hours accumulate that cannot be paid. See Common Mistakes New SDP Families Make.
Special Incident Reports and mandated reporting
Background checks are the front end of a larger safety system. Vendored providers, including the FMS, must file Special Incident Reports (SIRs) with the regional center when certain incidents occur. Caregivers are mandated reporters of abuse and neglect, which means they are legally required to report suspected abuse or neglect of the participant. What counts as a reportable incident, and the deadline for reporting it, is set by DDS and the regional center. Ask your service coordinator for the reporting instructions that apply to your caregivers, and make sure each caregiver knows them before they start.
How Sentinel Four handles this
- Background clearance is part of onboarding. Your dedicated case manager tells the caregiver what to do and where to go, and we do not set a start date until clearance is confirmed, unless the same-home family exemption applies.
- We collect onboarding documents and wage notices, set the caregiver up in ADP, and enable Electronic Visit Verification (EVV) clock-in through the AxisCare app only once the caregiver is cleared to work.
- Payroll runs weekly, paid on Mondays. Hours only flow to payroll for cleared, onboarded, authorized caregivers, so a caregiver who has not cleared cannot appear on a paycheck.
- Onboarding usually takes two to three weeks once documents and authorizations are in. A background check that is still pending is one of the common reasons it takes longer, so start it as soon as you have chosen a caregiver.
- As a vendored FMS we file Special Incident Reports when required, and your case manager can point a caregiver to where the mandated-reporter obligations are explained. See How Caregiver Payroll Works.
Questions about the Self-Determination Program?
Every Sentinel Four family has a dedicated case manager. Call 530-515-2948 or send us a message — we usually reply within one business day.
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