CHILD Act Expands Background Checks: Anyone Working with Government Contractors Now Subject to Federal Screening

The new Comprehensive Health and Integrity in Licensing and Documentation Act of 2025, or the CHILD Act, isn't about creating new programs; it's about tightening the security on existing ones. Specifically, Section 2 takes the federal background check requirements under the National Child Protection Act of 1993 and significantly broadens who must undergo screening. The core change is that the definition of a “covered individual”—someone who needs a background check—now includes people working for organizations that merely contract with a “qualified entity,” such as a county social services agency or a state licensing board.

Expanding the Safety Net: Who’s Covered Now

Think about it this way: before, if you worked directly for the state’s child protective services, you needed a background check. Now, if your non-profit provides after-school tutoring under contract with that same state agency, every single employee and volunteer at your non-profit is also considered a “covered individual” and must be vetted. This closes a potentially massive loophole where third-party contractors could have staff interacting with children without being subject to the same stringent federal screening as government employees. The goal is clearly to enhance child safety by making sure everyone who touches the system—even indirectly—is properly screened.

The Licensing Loophole Closure

The bill also extends the background check requirement to anyone seeking a license or certification from one of these qualified entities. Say you’re trying to get a state license to run a home daycare or a certification to be a specialized child therapist; you’ll now be subject to these federal checks as part of your application process. This is a crucial integrity measure: it ensures that the people the state officially approves to work with kids meet a higher standard of scrutiny before they ever open their doors. For parents, this is a clear win, offering greater assurance that licensed providers have been thoroughly vetted.

Real-World Impact and Administrative Headaches

While the benefit—increased child safety—is undeniable, this expansion isn't without friction. For small organizations and contractors who do business with state agencies, this means new administrative hurdles and costs. If a small transportation company contracts with the county to bus children to and from a specialized program, they now have to run federal background checks on all their drivers, mechanics, and potentially even administrative staff who might have access to sensitive records. This adds time and expense to their operations, which could ultimately be passed back to the government (and taxpayers) or affect the viability of smaller contractors. Furthermore, individuals seeking employment or licensing who might have previously slipped through the cracks will now face mandatory screening, potentially limiting access to these jobs or certifications if their background contains disqualifying information. The bill’s text doesn't define “qualified entity,” which leaves some wiggle room, but the intent is clear: if you’re involved in the child-serving ecosystem, expect Uncle Sam to check your paperwork.