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Child Clearances

Overview

All individuals who have a significant likelihood of interaction with children as part of an IRB approved protocol are required to obtain three clearances, at a minimum.  It is the responsibility of the principal investigator (PI) to ensure that the research team, including faculty, have these clearances prior to any interaction with children.  In addition, the PI is responsible for ensuring that appropriate supervision, guidance, and training occurs. If interactions with children occur outside of the Commonwealth of Pennsylvania, it is the responsibility of the PI to obtain the appropriate clearances in compliance with requirements set by the host state or country.  The definition of a child (age of majority) differs between states and countries and should be considered when determining when child clearances are required. Pennsylvania law defines a child as a person under 18 years of age

Description

The following three clearances are required by Pennsylvania law and/or UPMC and University policies:

  • Pennsylvania Department of Public Welfare Child Abuse Clearance History
  • Pennsylvania State Police Criminal Record Check
  • FBI Criminal Background Check

Information on obtaining the clearances is available through the Office of Human Resources Applying for Child Protection Clearances page.

Failure to comply with these requirements could result in a finding of serious non-compliance and may require reporting to state and/or federal agencies.   

Considerations

  • “Interact” refers not only to face-to-face meetings but also extends to communication via phone (including text messaging), social media or internet.  Conversely, a participating investigator or support staff member who does not have personal contact with children does not need to obtain clearances (e.g., statistician, non-clinical laboratory personnel, etc.).  If your research study provides babysitting services, the babysitters must have the required child clearances.
  • The requirement for child clearances does extend to clinical staff interacting with children. For instance, if a child undergoes a radiology procedure for research purposes, the individuals in that department would be required to have the child clearances.
  • At the time of an audit or any monitoring visit, the PI may be required to provide a listing of all research team members who interact with children and documentation that all clearances have been obtained and verified.   

Additional Resources

1/21/2021